Morneault v. Donovan
To prove unjust enrichment, a plaintiff must prove: 1.) the defendant was benefited; 2.) the defendant unjustly did not pay the plaintiff for the benefit; and 3.) the failure to pay was to the plaintiff's detriment. The court found the following facts by a preponderance of the evidence. Between 2000 and 2011, the parties resided together in a single-family residence. The plaintiff paid the defendant $200 per month, plus 50 percent of utilities. She also contributed to maintenance and to improvements in the amount of $11,197. Although the parties discussed the possibility of selling the residence and purchasing another property together, they remained together on the defendant's property until 2011, when the relationship deteriorated. At that time, the defendant commenced a summary-process action, and the plaintiff vacated the premises. In 2012, the defendant sold the residence and kept 100 percent of the net proceeds of sale. The plaintiff sued and argued that the defendant breached an oral contract to share the proceeds of sale. The court found that the plaintiff failed to prove that there was an oral contract. The parties' theoretical discussions about purchasing another residence, wrote the court, did not rise to the level of an enforceable contract. The plaintiff also sought to recover under the theory of unjust enrichment. The court found that the plaintiff failed to prove that the defendant's failure to reimburse the plaintiff for the plaintiff's contributions to maintenance and improvements was unjust. The plaintiff paid about $85 per month toward the maintenance and improvements, which resulted in payments for housing in the amount of $250 per month. This was a bargain and was a more generous deal than the plaintiff would have obtained in the housing market. The court granted judgment to the defendant.