Woodard & Curran, an environmental engineering company, helped the City of Baldwin pursue federal stimulus funding for wastewater-treatment improvements. A mayor signed a proposal authorizing additional design work, but Baldwin’s charter required written contracts reviewed by the city attorney and approved by the city council. The council never approved the proposal, and the city declined to pay for more than the initial funding-application work. A jury nevertheless awarded the company $203,000 on breach-of-contract and quantum-meruit theories. The Supreme Court of Georgia reversed. It held that the mayor could not unilaterally bind the city and that the unapproved proposal was an ultra vires contract, not merely a procedurally irregular one. Because an ultra vires municipal contract is void, the company could not recover in quantum meruit even though it performed work in reliance on the proposal. The court also held that the earlier $5,000 agreement covered only supporting documents for the funding application and was merely an agreement to negotiate future design services. To the extent earlier cases allowed quantum-meruit recovery in these circumstances, the court overruled them. The judgment was reversed.