Contracts I, Pages 208–214

Mitchell v. Moore

Superior Court of Pennsylvania, 1999

Facts:

Two men were in a romantic relationship on a farm. Plaintiff took care of defendant's farm partially until they broke up. Plaintiff alleged defendant promised him compensation for his services.

Procedural History:

Trial court denied defendants post-trial motions and entered judgment on a jury verdict of $130,000.

Issue:

Did the nature of the relationship rebut the presumption of unjust enrichment?

Rules:

  • A presumption of gratuitousness exists in familial and marriage-like relationships.

  • Gratuitous benefits do not constitute unjust enrichment.

Reasoning:

Defendant lived rent-free and got to be with plaintiff. He claimed to be doing it for their future and their relationship, not for reimbursement.

Holding:

Plaintiff did not "wrongfully secure a benefit that is unconscionable for him to retain." Trial court's verdict reversed. Denial of counterclaim affirmed.

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