Quantum meruit for the subcontractor: Has restitution jumped off off Dawson's dock?

This article uses a hypothetical case of a quantum merit claim to examine the search for limiting principles. By positing an unfortunate dunking in store for the judge who relies on broad unjust enrichment principles, Professor John Dawson's analogy supports absolute rules, rules designed to keep the judge "on the dock." The aquatic pratfall that follows a decision of another important point: the need for judicial flexibility and creativity. Although the author agrees with Dawson's main idea - the need for intermediate limitations on unjust enrichment - he is skeptical about the absolutism suggested by the view from Dawson's dock. A frame of reference for restitution disputes that will respect the dignity of limitations yet preserve a safety value for creative and individual decision making, depending on the facts and context is proposed.