Sparks v. Gustafson

750 P.2d 338 (Alaska 1988)



Unjust enrichment exists where the defendant has received a benefit from the plaintiff and it would be inequitable for defendant to retain the benefit without compensating plaintiff for its value.


Plaintiff manager alleged a breach of an oral contract by the defendant executor and estate and later filed an amended complaint, which alleged that plaintiff was entitled to recover for funds and services that he expended on the building under an equitable lien theory. At trial, the superior court found that it was inequitable to allow the estate to retain the benefits that plaintiff had conferred upon the property at his own expense and, therefore, ordered the estate to pay plaintiff compensation. On appeal, the state supreme court affirmed the trial court's order.


Was the estate of defendant executor liable to pay plaintiff manager compensation for management services that he rendered to the estate and for maintaining and improving the estate property?




The trial court did not err in awarding plaintiff manager damages under an unjust enrichment theory because, although the complaint did not clearly encompass the theory, it was tried with the express or implied consent of defendant executor. Plaintiff was entitled to compensation because the services that he performed for the estate were the types of extensive business services for which one would ordinarily expect to be paid.

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