n3 We recognize that at common law a plaintiff who willfully breached a contract could not recover restitution of his or her part performance. Schmidt v. North Yakima, 12 Wash. 121, 40 P. 790 (1895) (contractor who willfully and fraudulently refuses to comply with contract cannot recover); Swenson v. Lowe, 5 Wash. App. 186, 486 P.2d 1120 (1971) (restating Schmidt rule). Restatement 2d and many jurisdictions reject the common law rule, allowing a defaulting party to recover for any benefit that he or she has conferred in excess of the loss caused by his or her own breach. Restatement 2d § 374(1) (1979). Lancellotti v. Thomas, 341 Pa. Super. 1, 491 A.2d 117 (1985) (tracing the demise of the common law rule).