The Court found that where services are rendered under an express contract, there can be no quasi-contractual recovery through the theory of quantum meruit. In this action, there was one count based on breach of an express contract and another on the theory of quantum meruit. Each of these Counts sought recovery for the same services. Once the existence of an express contract for the services at issue had been established, the trial court property dismissed the Count seeking recovery under quantum meruit. Installco Inc. v. WHiting Corp., No. 1-02-0244, 784 N.E.2d 304, 271 Ill. Dec. 86 (1st Dist. Dec. 26, 2002).
