Larisa’s Home Care, LLC v. Nichols-Shields

A person’s estate is unjustly enriched if the person receives benefits through misrepresentations about his or her finances. In re Anderson’s Estate, 157 Or 365, 71 P2d 1013 (1937).

Plaintiff, Larisa’s Home Care, LLC., appealed a Court of Appeals decision that held the estate of one of the facility’s patients, Prichard, was not unjustly enriched based upon the three factors listed in Jaqua v. Nike, Inc., 125 Or App 294, 298, 865 P2d 442 (1993). On appeal, Plaintiff argued that but for Medicaid fraud, Prichard would not have qualified for a lower rate, and therefore, the estate was unjustly enriched about $50,000 in saved care expenses. A person’s estate is unjustly enriched if the person receives benefits through misrepresentations about his or her finances. In re Anderson’s Estate, 157 Or 365, 71 P2d 1013 (1937). The Oregon Supreme Court rejected the Jaqua factors, finding the formula to be insufficient to determine if Prichard’s estate was unjustly enriched. The Court found Prichard qualified for the Plaintiff’s lower rate for Medicaid patients through false representations, and ultimately concluded that allowing her beneficiaries to retain the benefits gain through fraud would constitute unjust enrichment. The decision of the Court of Appeals is reversed, and the case is remanded to the Court of Appeals for further proceedings.