Jerry Berardi and Betty Berardi v. Jack L. Oliver, CPA, d/b/a Oliver & Associates, Accountants and Consultants

Summary

The West Virginia Supreme Court of Appeals affirmed a circuit court judgment awarding Jack L. Oliver, CPA, $26,300 plus costs under a quantum meruit theory for professional accounting services provided to Jerry and Betty Berardi. The Court held that the circuit court complied with West Virginia Rule of Civil Procedure 52(a) and that substantial evidence supported its finding that the submitted invoices were fair and reasonable.

Holdings

1. No. The circuit court could award quantum meruit compensation without making a specific finding of the exact number of hours worked because substantial evidence established the extent and difficulty of the services and supported the finding that Oliver's invoices were fair and reasonable.
2. Yes. Rule 52 does not require a specific finding of the number of hours spent on each service when the court's findings adequately identify the factual basis for the award and its conclusions are supported by substantial evidence.

Questions Presented

1. Whether the circuit court properly awarded compensation under quantum meruit when the record did not specify the exact number of hours Oliver spent performing the services.
2. Whether the circuit court complied with West Virginia Rule of Civil Procedure 52(a) by making sufficient findings of fact and conclusions of law to support its judgment.

Disposition

affirmed