Legal Question in Civil Litigation in California

Q. M. is a measure of what the damages to be awarded should be, so there is no statue of limitations as it is not a cause of action.

In California the equitable remedy of quantum meruit is not recognized per se. Instead it is codified and referred to under the general name "common counts." The limitations on common counts is two years if the basis of the transaction is a verbal exchange, and four years if there is a written record.