unjust enrichment claim in Minnesota

2024Id. at 729-30 (reversing the summary-judgment dismissal of the appellant’s unjust-enrichment claim when he “provided evidence that he made substantial improvements on respondents’ land, that respondents knew of those improvements and either encouraged them or did nothing to discourage them and that respondents have benefited from them,” creating a genuine issue of material fact).

2015Id. (discussing illegal or unlawful enrichment); Schumacher, 627 N.W.2d at 729-30 (extending the doctrine of unjust enrichment to morally wrong acts); Anderson v. DeLisle, 352 N.W.2d 794, 796 (Minn. App. 1984) (recognizing that fraud may form the basis of an unjust-enrichment claim).

2016Paul v. Ramier, 311 N.W.2d 502, 504 (Minn. 1981) (quotation omitted); see Park-Lake Car Wash, Inc. v. Springer, 394 N.W.2d 505, 514 (Minn. App. 1986) (stating that “unjust” can also mean “unconscionable by reason of a bad motive” (quotation omitted)).

2015Id. (discussing illegal or unlawful enrichment); Schumacher, 627 N.W.2d at 729-30 (extending the doctrine of unjust enrichment to morally wrong acts); Anderson v. DeLisle, 352 N.W.2d 794, 796 (Minn. App. 1984) (recognizing that fraud may form the basis of an unjust-enrichment claim).

2025See Hepfl, 9 N.W.3d at 572 (overruling Park-Lake Car Wash, Inc. v. Springer, 394 N.W.2d 505 (Minn. App. 1986)).

2016Paul v. Ramier, 311 N.W.2d 502, 504 (Minn. 1981) (quotation omitted); see Park-Lake Car Wash, Inc. v. Springer, 394 N.W.2d 505, 514 (Minn. App. 1986) (stating that “unjust” can also mean “unconscionable by reason of a bad motive” (quotation omitted)).

2015Id. (discussing illegal or unlawful enrichment); Schumacher, 627 N.W.2d at 729-30 (extending the doctrine of unjust enrichment to morally wrong acts); Anderson v. DeLisle, 352 N.W.2d 794, 796 (Minn. App. 1984) (recognizing that fraud may form the basis of an unjust-enrichment claim).

1996An unjust enrichment claim may be founded upon failure of consideration, fraud, or mistake, or “situations where it would be morally wrong for one party to enrich himself at the expense of another.” Id. (citing Anderson v. DeLisle, 352 N.W.2d 794, 796 (Minn.App.1984), review denied (Minn. Nov. 8, 1984)).

2012Cloud v. GAB Business Services, Inc., we explained: To establish an unjust enrichment claim, the claimant must show that the defendant has knowingly received or obtained something of value for which the defendant in equity and good conscience should pay. [UJnjust enrichment claims do not lie simply because one party benefits from the efforts or obligations of others, but instead it must be shown that a party was unjustly enriched in the sense that the term unjustly could mean illegally or unlawfully. 544 N.W.2d 302, 306 (Minn.1996) (internal quotation marks omitted) (citations omitted).

2010An unjust-enrichment claim requires proof that a party “was unjustly enriched in the sense that the term ‘unjustly’ could mean illegally or unlawfully,” id., or as a result of fraudulent inducement or unconscionable conduct, Schumacher v. Schumacher, 627 N.W.2d 725, 729-30 (Minn.App.2001).

2025See Hepfl, 9 N.W.3d at 571 (stating that “mere enrichment”—which occurs when “one party benefits from the efforts or obligations of others”—does not suffice to establish unjust enrichment (quoting First Nat’l Bank of St.

2025See Hepfl, 9 N.W.3d at 571. 11 1336573, at *4-5; Nofar, 2024 WL 5148061 , at *11-13.

2024See Herlache, 990 N.W.2d at 450 (when bringing an unjust enrichment claim, a “plaintiff must show that the defendant was enriched illegally or unlawfully or in a manner that is morally wrong” (citation omitted) (internal quotation marks omitted)); Caldas v. Affordable Granite & Stone, Inc., 820 N.W.2d 826, 838 (Minn. 2012) (unjust enrichment “allows a plaintiff to recover a benefit conferred upon a defendant when retention of the benefit is not legally justifiable”); see also Herlache, 990 N.W.2d at 450 (recognizing that unjust enrichment developed from a common law cause of action called “mon

2012Brand v. Williams, 29 Minn. 238, 239 , 13 N.W. 42, 42 (1882).

2016“Unjust enrichment requires that: (1) a benefit be conferred by the plaintiff on the defendant; (2) the defendant accept the benefit; (3) the defendant retain the benefit although retaining it without payment is inequitable.” Zinter v. Univ. of Minn., 799 N.W.2d 243, 247 (Minn. App. 2011), review denied (Minn. Aug. 16, 2011).

2015The elements of an unjust-enrichment claim are that: “(1) a benefit be conferred by the plaintiff on the defendant; (2) the defendant accept the benefit; (3) the defendant retain the benefit although retaining it without payment is inequitable.” Zinter v. Univ. of Minn., 799 N.W.2d 243, 247 (Minn. App. 2011), review denied (Minn. Aug. 16, 2011). “[T]o prevail on a claim of unjust enrichment, a claimant must establish an implied-in- law or quasi-contract in which the defendant received a benefit of value that unjustly enriched the defendant in a manner that is illegal or unlawful,” Caldas, 820

2024See Herlache, 990 N.W.2d at 450 (when bringing an unjust enrichment claim, a “plaintiff must show that the defendant was enriched illegally or unlawfully or in a manner that is morally wrong” (citation omitted) (internal quotation marks omitted)); Caldas v. Affordable Granite & Stone, Inc., 820 N.W.2d 826, 838 (Minn. 2012) (unjust enrichment “allows a plaintiff to recover a benefit conferred upon a defendant when retention of the benefit is not legally justifiable”); see also Herlache, 990 N.W.2d at 450 (recognizing that unjust enrichment developed from a common law cause of action called “mon

2015The elements of an unjust-enrichment claim are that: “(1) a benefit be conferred by the plaintiff on the defendant; (2) the defendant accept the benefit; (3) the defendant retain the benefit although retaining it without payment is inequitable.” Zinter v. Univ. of Minn., 799 N.W.2d 243, 247 (Minn. App. 2011), review denied (Minn. Aug. 16, 2011). “[T]o prevail on a claim of unjust enrichment, a claimant must establish an implied-in- law or quasi-contract in which the defendant received a benefit of value that unjustly enriched the defendant in a manner that is illegal or unlawful,” Caldas, 820

2016We explained that the district court did not have subject- matter jurisdiction over an unjust-enrichment claim brought by the county because “the outcome of the claim” depended “upon the validity of [a] . . . quasi-judicial decision.” Id. 3 It is true that we characterized the defamation claims from Willis v. County of Sherburne, as “separate and distinct” from the County’s decision to terminate Willis’s employment. 555 N.W.2d 277, 282 (Minn. 1996).

2012The County further relies on Willis v. County of Sherburne, 555 N.W.2d 277 (Minn.1996), to argue that an unjust enrichment claim is not subject to certiora-ri review.

2026However, “[e]quitable relief is available only upon a showing that no adequate legal remedy exists.” Stocke v. Berryman, 632 N.W.2d 242, 245-46 (Minn. App. 2001), rev. denied (Minn. Sept. 25, 2001).

2026See Block, 428 N.W.2d at 851, 854 (concluding that the statute of limitations for an unjust-enrichment claim began to run when the first overpayment on a contract was made).

2026See Block, 428 N.W.2d at 851, 854 (concluding that the statute of limitations for an unjust-enrichment claim began to run when the first overpayment on a contract was made).

2025See Demskie v. U.S. Bank Nat’l Ass’n, 7 N.W.3d 382, 387 (Minn. 2024) (“[T]he Minnesota pleading standard requires only information sufficient to fairly notify the opposing party of the claim against it, with a focus on the underlying incident rather than on the specific facts of the incident.” (quotations omitted)).

2024See Freberg, 228 N.W. at 160 (“The plaintiff may be denied relief where his conduct has been unconscionable by reason of a bad motive, or where the result induced 2 Given the inverted procedural posture of the unjust enrichment claim in Park-Lake, in which a defendant claimed that a plaintiff would be unjustly enriched in the absence of an offset to damages, that case refers to “a plaintiff’s conduct.” In this case, Meadowcroft was the party against whom the unjust enrichment claim was brought, so the district court’s amended order and court of appeals’ decision both applied this passage from

2016Hammes West argues that the district court erred as a matter of law by dismissing its unjust-enrichment claim because an unjust-enrichment claim can survive a cancellation of a contract for deed under Minnesota law.1 “[S]tatutory cancellation does not preclude a suit for unjust enrichment brought by a defaulting vendee.” Fort Dodd P’ship v. Trooien, 392 N.W.2d 46, 48 (Minn. App. 1986).

2016“The theory of unjust enrichment . . . has been used to support claims based upon failure of consideration, fraud in the inducement of the contract, mistake, or other situations where it would be morally wrong for one party to enrich itself at the expense of others.” Id.; see also Miller v. Anderson, 394 N.W.2d 279, 283 (Minn. App. 1986) (“Although the statutory cancellation of a contract for deed does not preclude a claim of unjust enrichment, [vendees] must make a threshold showing of fraud, mistake, or moral wrongdoing on the part of the contract for deed vendor.”). 1 Only the unjust-enrich

2016“The theory of unjust enrichment . . . has been used to support claims based upon failure of consideration, fraud in the inducement of the contract, mistake, or other situations where it would be morally wrong for one party to enrich itself at the expense of others.” Id.; see also Miller v. Anderson, 394 N.W.2d 279, 283 (Minn. App. 1986) (“Although the statutory cancellation of a contract for deed does not preclude a claim of unjust enrichment, [vendees] must make a threshold showing of fraud, mistake, or moral wrongdoing on the part of the contract for deed vendor.”). 1 Only the unjust-enrich

2015See Gillette v. Storm Circle Ranch, 619 P.2d 1116, 1120 (Idaho 1980) (reversing judgment on unjust-enrichment claim because plaintiff introduced evidence of his costs but not evidence of value of defendant’s benefit); Management Computer Servs., Inc. v. Hawkins, Ash, Baptie & Co., 557 N.W.2d 67, 79-80 (Wis. 1996) (reversing judgment on 3 Positive did not employ an expert witness to analyze the financial evidence and provide opinion evidence of the amount of Uppal’s enrichment.

2015Reynolds Tobacco Co., 742 N.W.2d 186, 195-96 (Minn. App. 2007), review denied (Minn. Jan. 20, 2009).

2015See Gillette v. Storm Circle Ranch, 619 P.2d 1116, 1120 (Idaho 1980) (reversing judgment on unjust-enrichment claim because plaintiff introduced evidence of his costs but not evidence of value of defendant’s benefit); Management Computer Servs., Inc. v. Hawkins, Ash, Baptie & Co., 557 N.W.2d 67, 79-80 (Wis. 1996) (reversing judgment on 3 Positive did not employ an expert witness to analyze the financial evidence and provide opinion evidence of the amount of Uppal’s enrichment.

2014City of N. Oaks v. Sarpal, 797 N.W.2d 18, 23 (Minn. 2011).

2011ANALYSIS “The existence of subject matter jurisdiction is a question of law, which this court reviews de novo.” Shaw v. Bd. of Regents, 594 N.W.2d 187, 190 (Minn.App.1999), review denied (Minn. July 28, 1999).

2007Co. v. State, 383 N.W.2d 416, 417 (Minn.App.1986), review denied (Minn. May 22, 1986).

1992In re Stevenson Assocs., Inc., 777 F.2d 415, 421 (8th Cir.1985); Ylijarvi v. Brockphaler, 213 Minn. 385, 393 , 7 N.W.2d 314, 319 (1942).

1992In re Stevenson Assocs., Inc., 777 F.2d 415, 421 (8th Cir.1985); Ylijarvi v. Brockphaler, 213 Minn. 385, 393 , 7 N.W.2d 314, 319 (1942).

1992In re Stevenson Assocs., Inc., 777 F.2d 415, 421 (8th Cir.1985); Ylijarvi v. Brockphaler, 213 Minn. 385, 393 , 7 N.W.2d 314, 319 (1942).