Mitchell v. Moore

1999 PA Super 77, 729 A.2d 1200



"Unjust enrichment" is essentially an equitable doctrine. Where unjust enrichment is found, the law implies a contract, which requires the defendant to pay to the plaintiff the value of the benefit conferred. The elements necessary to prove unjust enrichment are: (1) benefits conferred on defendant by plaintiff; (2) appreciation of such benefits by defendant; and (3) acceptance and retention of such benefits under such circumstances that it would be inequitable for defendant to retain the benefit without payment of value. The application of the doctrine depends on the particular factual circumstances of the case at issue. In determining if the doctrine applies, a court's focus is not on the intention of the parties, but rather on whether the defendant has been unjustly enriched.


In an action asserting claims for quantum meruit and implied contract, a judgment awarding damages to plaintiff and denying defendant's counterclaim was reversed in part and affirmed in part. Plaintiff sued on a theory of unjust enrichment after the parties' romantic relationship ended. Plaintiff sought compensation for services rendered, including work on defendant's farm and in an antique cooperative, and sought compensation for contributions toward a real estate purchase. Defendant's counterclaim sought rent for the time plaintiff lived on his farm, plus compensation for various bills paid on plaintiff's behalf.


Is the plaintiff entitled to be paid for the services he rendered to defendant during their romantic relationship under the doctrine of unjust enrichment?




The court held that in order to prove defendant was unjustly enriched by plaintiff's services, there had to be some convincing evidence establishing that the services were not gratuitous. According to the court, the benefits that plaintiff received from living at defendant's farm rebutted any presumption that the benefit conferred upon defendant was unjust. Plaintiff was not entitled to recover compensation for services rendered where there was no evidence that his services were not gratuitous. For the same reason, defendant's counterclaim was properly dismissed.

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