Grimstad v. Knudsen

Plaintiff may prove an unjust enrichment claim without showing that Plaintiff conferred a benefit on Defendant, but instead by showing that Defendant received a benefit from a third party.

Defendants appealed summary judgment in favor of Plaintiffs for unjust enrichment. Trial court found that Defendants were unjustly enriched by Plaintiffs where Defendants, as power of attorney for Decedent, sold a property that was left to Plaintiffs in Decedent’s will, and used the proceeds to pay for the care of Decedent. Defendants argued that the trial court erred in granting summary judgment for unjust enrichment because the first element of an unjust enrichment claim requires the plaintiff to prove that the plaintiff conferred a benefit on the defendant. Following Tupper, the Court found that a plaintiff may, in some circumstances, bring an unjust enrichment claim even if the plaintiff did not confer a benefit on the defendant. For a third-party defendant, Tupper requires a plaintiff to demonstrate that the defendant has obtained “property or a property interest that rightfully belonged” to the plaintiff. However, the Court found that the trial court did err in granting summary judgment because Decedent’s actions indicating that she wished Plaintiffs to have the property were not sufficient to establish that Plaintiffs had any legal or equitable right to the proceeds of the sale of the property. Reversed and remanded.