Martin v. Little, Brown & Co. 304 Pa.Super. 424, 450 A.2d 984 (Pa.Super. 1981) Martin sent a letter to Little telling them that one of their books had been plagiarized.  When Little sued the third party infringer, Martin demanded compensation for his help.  Little sent him $200, but he sued for one-third of Little's recovery in the infringement suit and for intentional infliction of mental distress based on Little's threat to countersue him. Martin never requested payment for his services in his original letter.  He simply offered to volunteer information to Little. Martin made the claim pro se, that means he didn't have a lawyer. Little demurred all the facts.  That means that even if all the facts are true, the law still says they should win. The Trial Court ruled that there had been no contract made and that Martin could not recover for quantum meruit because he had acted as a "volunteer". The Trial Court dismissed the intentional infliction of mental distress claim.  Getting stressed out because someone threatens to countersue you is not a legitimate, recoverable claim.  If it was, then all litigation would involve a mental distress tort. The Appellate Court affirmed the decision. In order to construe an implied contract from a course of conduct between two parties, an intention to pay on the part of the alleged promisee must be reasonably inferable. In the absence of a contract, restitution is only available when someone has been "unjustly enriched at the expense of another." Volunteers generally have no right to restitution. The Court found nothing in the course of conduct between the parties that suggested that Martin demanded money or that Little expressed a willingness or expectation to pay for Martin's service. The Court found that the Martin was a volunteer.  Therefore, Little may have been enriched, but not unjustly. Martin's benefit was given more in the nature of a gift. The Court found that, "where circumstances are evident that one's work effort has been voluntarily given to another, an intention to pay therefore cannot be inferred."  Basically, as a general rule, volunteers have no right to restitution or compensation for their services.