It is common knowledge in the legal community that the Statute of Frauds can preclude recovery on an action for breach of contract. However, claims for breach of contract are typically accompanied by some alternative claim should the court find that the contract was unenforceable, such as restitution or quantum meruit. That begs the question of whether the Statute of Frauds would apply to such an alternative claim not based on the purported contract.

http://jimersoncobb.com/blawg/2011/10/25/does-the-statute-of-frauds-apply-to-a-claim-based-on-quantum-meruit/