The principle of unjust enrichment is that the plaintiff suffers economic damage for which he is not responsible, while the defendant receives an economic benefit for which he has not paid. An action for unjust enrichment is allowed only when the plaintiff has no other remedy at law.
Plaintiff entered into a contract with defendant's lessee to clean up a spill of "wash water." Lessee ceased operations without paying the full amount due. Plaintiff sued defendant for unjust enrichment, in order to recover a balance due for environmental cleanup work. The trial court reserved the contractor's claim that the owner specifically agreed to pay a portion of the rental of storage boxes containing material removed from the site, but found that the owner was not liable for the remaining amount. The trial court granted partial summary judgment, and plaintiff appealed from the grant.
Whether the plaintiff could successfully bring a suit for unjust enrichment against the defendant?
No, the plaintiff could not bring a suit for unjust enrichment against the defendant.
In affirming the lower court's ruling, the appellate Court held that the owner was not liable since the contractor failed to demonstrate that the material in question was hazardous. Just because the material did not meet the water discharge quality standards did not make it hazardous. The plaintiff could not bring an unjust enrichment action because a remedy at law was available against the lessee. Plaintiff also could not establish a quasi contract, since the plaintiff had not voluntarily undertaken management of another's affairs.