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The doctrine of unjust enrichment is an equitable one, providing that one party should not be allowed to benefit at the expense of another because of an innocent mistake or unintentional error.
The buyer purchased the leased farmland and harvested the wheat crops that were planted by the tenant. The buyer refused the executrix's demand for payment of the cost of planting the seed, contending that the wheat crops were part of the real estate purchase. The trial court found that the buyer was unjustly enriched because he aware that the wheat crop was planted at the time of the purchase, that the value of the wheat crop did not enter into the negotiations on the selling price, and that the tenant was unaware of the proposed sale of the land to the buyer. On appeal, the buyer contended that the executrix was not entitled to recovery because the tenant planted the wheat only a few months before the lease was to expire and knew that it would not mature during the period of the lease.
Under the circumstances, was the executrix entitled to recover the costs of planting the wheat on the buyer’s farm, thereby warranting the judgment in favor of the executrix?
The court affirmed the judgment of the trial court, holding that the tenant's estate was entitled to recover the costs of planting the wheat on the buyer's farm because the buyer would unjustly reap the benefits of the tenant's labor and expense. While the tenant had no legal or equitable claim to the wheat crop, the buyer was not entitled to be unjustly enriched in the amount expended to plant the crop.