## Facts

- In 1934, six large murals were commissioned and installed on canvas affixed to walls at a public high school building later owned by the City of Stamford.
- During a 1970 renovation, workers removed the murals and left them outside with construction debris; a recent graduate retrieved and stored them.
- In 1971, the murals were transferred to a federal fine-arts inventory supervisor, who placed them with Hiram Hoelzer, a professional art restorer.
- The murals arrived in poor condition (wet, dirty, and damaged). In 1972, Hoelzer wrote seeking instructions about restoration; no response was received.
- Hoelzer nonetheless stabilized and restored the murals over many years, repeatedly requesting direction and compensation without receiving a response.
- In the 1980s, the City sought to locate and recover the murals for display; City representatives visited Hoelzer’s studio and knew he was restoring them.
- The murals were later appraised at about $1.25 million. Hoelzer refused to surrender them without recognition of ownership or compensation.
- Hoelzer sued in federal court seeking title or, alternatively, compensation for restoration and safekeeping.
- A partial judgment determined the City held title; after remand for compensation, the district court awarded Hoelzer $557,200 in quantum meruit.
- The City appealed, challenging Hoelzer’s entitlement to equitable relief and the amount of the award.

## Issues

1. Whether Hoelzer acted in sufficient good faith to qualify for quantum meruit restitution for restoring property owned by the City.
2. Whether the $557,200 quantum meruit award was clearly erroneous as exceeding the benefit conferred or otherwise being excessive.
3. Whether equitable considerations permitted modifying the judgment to allow satisfaction by transferring the murals to Hoelzer instead of paying cash.

## Decision

- The Second Circuit affirmed the quantum meruit award, rejecting the City’s arguments that Hoelzer lacked good faith and that the award was excessive.
- The court held the district court did not clearly err in finding Hoelzer’s restoration services conferred substantial value and warranted restitution measured by the reasonable value of services.
- The court directed modification of the judgment to permit the City to satisfy the award by returning the murals to Hoelzer within a reasonable time set by the district court.

## Legal Principles

- Quantum meruit may award restitution for the reasonable value of services that confer a measurable benefit, even absent a contract, to prevent unjust enrichment.
- A claimant’s good-faith belief in authorization or entitlement can support restitution for improving or preserving another’s property, particularly where the owner failed to protect the property and later seeks the enhanced asset.
- Appellate review of a quantum meruit valuation is for clear error when the award rests on factual findings supported by evidence (including expert testimony and comparable restoration fees).
- Equitable remedies are flexible; a court may structure relief to balance interests, including allowing satisfaction of a monetary judgment by transferring the improved property.

## Conclusion

The court held that a professional restorer who, in good faith, preserved and restored city-owned murals was entitled to quantum meruit compensation based on the reasonable value of his services, and it permitted the City to discharge the award by returning the murals to him within a court-set timeframe.


Hoelzer v. City of Stamford, 972 F.2d 495 (2d Cir. 1992)