Mitchell v. Moore
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.