Cotnam v. Wisdom, 104 S.W. 164 (Ark. 1907) is a case where a doctor rendered emergency services to an unconscious payment, who died without recovering consciousness. In re Crisan Estate, 107 N. W.2d 907 (Mich. 1961) is a similar case involving a hospital. Farnsworth, in whose Contracts I found these examples, comments that "The reader who wonders what effect the patient's religious scruples regarding medical treatment might have will have to be content with the Michigan court's comment that "there is surprisingly little case authority to be found" in this area. (p. 104 fn 27).

Such cases are sometimes referred to as involving "restitution" (someone has performed a valuable service and deserves to be compensated), "quasi-contract," or as being in "quantum meruit."