unjust enrichment claim (Idaho) · Go Syfert
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unjust enrichment claim in Idaho

23 Idaho opinions name it 2 courts 1984–2026 3 in the last five years

The cases below were cited by Idaho courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (15)

CaseFollowedCited
Idaho Lumber, Inc. v. Buckgreen
idahoctapp · 1985 · cited in 4 Idaho opinions naming this issue, 1994–2017
2 sentences

2017Id.

1995Continental Forest Products, Inc. v. Chandler Supply Co., 95 Idaho 739, 743 , 518 P.2d 1201, 1205 (1974); Idaho Lumber, Inc. v. Buck, 109 Idaho 737, 744 , 710 P.2d 647, 654 (Ct.App.1985).

34
Continental Forest Products, Inc. v. Chandler Supply Co.green
idaho · 1974 · cited in 4 Idaho opinions naming this issue, 1994–1999
2 sentences

1999In this regal’d, the district court misapplied Dale’s Service Co., Inc. v. Jones, 96 Idaho 662 , 534 P.2d 1102 (1975), and incorrectly created a distinction between an action for quantum meruit and unjust enrichment because both quantum meruit and unjust enrichment do involve claims based on an implicit promise to pay. 7 In Continental Forest Products, Inc. v. Chandler Supply Co., 95 Idaho 739 , 518 P.2d 1201 (1974), this Court recognized three types of contractual arrangements: First is the express contract wherein the parties expressly agree regarding a transaction.

1999In this regal’d, the district court misapplied Dale’s Service Co., Inc. v. Jones, 96 Idaho 662 , 534 P.2d 1102 (1975), and incorrectly created a distinction between an action for quantum meruit and unjust enrichment because both quantum meruit and unjust enrichment do involve claims based on an implicit promise to pay. 7 In Continental Forest Products, Inc. v. Chandler Supply Co., 95 Idaho 739 , 518 P.2d 1201 (1974), this Court recognized three types of contractual arrangements: First is the express contract wherein the parties expressly agree regarding a transaction.

34
Beco Construction Co. v. Bannock Paving Co.green
idaho · 1990 · cited in 3 Idaho opinions naming this issue, 2003–2009
2 sentences

2009Co., Inc. v. Bannock Paving Co., Inc., 118 Idaho 463, 466 , 797 P.2d 863, 866 (1990).

2009Co., Inc. v. Bannock Paving Co., Inc., 118 Idaho 463, 466 , 797 P.2d 863, 866 (1990).

23
Hausam v. Schnablgreen
idahoctapp · 1994 · cited in 4 Idaho opinions naming this issue, 1997–2012
2 sentences

2012In Hausam , Schnabl entrusted his son with the operation of his company, RW Logging, giving the son “unfettered ability to pay himself whatever he wanted.” 126 Idaho at 571 , 887 P.2d at 1078 .

2012In Hausam , Schnabl entrusted his son with the operation of his company, RW Logging, giving the son “unfettered ability to pay himself whatever he wanted.” 126 Idaho at 571 , 887 P.2d at 1078 .

14
Thomas v. Thomasgreen
idaho · 2011 · cited in 2 Idaho opinions naming this issue, 2015–2026
2 sentences

2026The Estate next contends that Rule 8 of the Idaho Rules of Civil Procedure permits pleading unjust enrichment in the alternative, citing Thomas v. Thomas, 150 Idaho 636, 644 , 249 P.3d 829, 837 (2011).

2026The Estate next contends that Rule 8 of the Idaho Rules of Civil Procedure permits pleading unjust enrichment in the alternative, citing Thomas v. Thomas, 150 Idaho 636, 644 , 249 P.3d 829, 837 (2011).

12
Great Plains Equipment, Inc. v. Northwest Pipeline Corp.green
idaho · 2001 · cited in 2 Idaho opinions naming this issue, 2008–2011
2 sentences

2011It is true that a fee award was denied to Northwest Pipeline (NWP), the prevailing party in Great Plains, even though the losing party, Cate-Idaho, had claimed it was entitled to attorney fees under I.C. § 12-120(3) with regard to an unjust enrichment claim, upon which it subsequently failed to recover. 136 Idaho at 472 , 36 P.3d at 224 (“In this case, attorney fees were requested for the separate claim of unjust enrichment pursuant to I.C. § 12-120(3), and the gravamen of that claim was a commercial transaction.”).

2011It is true that a fee award was denied to Northwest Pipeline (NWP), the prevailing party in Great Plains, even though the losing party, Cate-Idaho, had claimed it was entitled to attorney fees under I.C. § 12-120(3) with regard to an unjust enrichment claim, upon which it subsequently failed to recover. 136 Idaho at 472 , 36 P.3d at 224 (“In this case, attorney fees were requested for the separate claim of unjust enrichment pursuant to I.C. § 12-120(3), and the gravamen of that claim was a commercial transaction.”).

12
Hertz v. Fiscusgreen
idaho · 1977 · cited in 2 Idaho opinions naming this issue, 1985–2003
2 sentences

2003Beco Construction Co. v. Bannock Paving Co., 118 Idaho 463, 466 , 797 P.2d 863, 866 (1990) (quoting Hertz v. Fiscus, 98 Idaho 456, 457 , 567 P.2d 1, 2 (1977)).

2003Beco Construction Co. v. Bannock Paving Co., 118 Idaho 463, 466 , 797 P.2d 863, 866 (1990) (quoting Hertz v. Fiscus, 98 Idaho 456, 457 , 567 P.2d 1, 2 (1977)).

12
Bishop v. Owensgreen
idaho · 2012 · cited in 1 Idaho opinions naming this issue, 2026–2026
2 sentences

2026See Bishop, 152 Idaho at 620 , 272 P.3d at 1251 .

2026See Bishop, 152 Idaho at 620 , 272 P.3d at 1251 .

11
Brown & Brown, Inc. v. Colagreen
paed · 2010 · cited in 1 Idaho opinions naming this issue, 2026–2026
1 sentence

2026See id.

11
Johnson v. McPheegreen
idahoctapp · 2009 · cited in 1 Idaho opinions naming this issue, 2011–2011
2 sentences

2011Johnson v. McPhee, 147 Idaho 455, 466 , 210 P.3d 563, 574 (2009) (“We may affirm the district court if we conclude that summary judgment on this cause of action would have been proper on an alternative basis.”) The written contracts were entered into by the parties in 2000 and thereafter governed both Drew’s salary and the promise to convey Thomas Motors.

2011Johnson v. McPhee, 147 Idaho 455, 466 , 210 P.3d 563, 574 (2009) (“We may affirm the district court if we conclude that summary judgment on this cause of action would have been proper on an alternative basis.”) The written contracts were entered into by the parties in 2000 and thereafter governed both Drew’s salary and the promise to convey Thomas Motors.

11
Ridgeline Constructors, Inc. v. Elmira Glass Technology Corp.green
nyappdiv · 1992 · cited in 1 Idaho opinions naming this issue, 2011–2011
2 sentences

2011Carp., 183 A.D.2d 1041 , 583 N.Y.S.2d 633, 635 (1992) (“With respect to the unjust enrichment claim, because recovery is dependent upon how the contract claim is resolved, it is ... not capable of disposition on a summary judgment motion.”); Fed.

2011Carp., 183 A.D.2d 1041 , 583 N.Y.S.2d 633, 635 (1992) (“With respect to the unjust enrichment claim, because recovery is dependent upon how the contract claim is resolved, it is ... not capable of disposition on a summary judgment motion.”); Fed.

11
Willie v. Board of Trusteesgreen
idaho · 2002 · cited in 1 Idaho opinions naming this issue, 2008–2008
2 sentences

2008No. 351, 138 Idaho 131, 136 , 59 P.3d 302, 307 (2002) ("Under I.C. § 12-120(3), the prevailing party in a civil action involving a commercial transaction based on a contract is entitled to an award of reasonable attorney fees"); Great Plains Equip., Inc. v. Northwest Pipeline Corp., 136 Idaho 466 , 36 P.3d 218 (2001) (gravamen of an unjust enrichment claim can be a commercial transaction).

2008No. 351, 138 Idaho 131, 136 , 59 P.3d 302, 307 (2002) ("Under I.C. § 12-120(3), the prevailing party in a civil action involving a commercial transaction based on a contract is entitled to an award of reasonable attorney fees"); Great Plains Equip., Inc. v. Northwest Pipeline Corp., 136 Idaho 466 , 36 P.3d 218 (2001) (gravamen of an unjust enrichment claim can be a commercial transaction).

11
Dietrich v. Copeland Lumber Co.green
idaho · 1916 · cited in 1 Idaho opinions naming this issue, 2005–2005
2 sentences

2005The district court cited to Dietrich v. Copeland Lumber Co., 28 Idaho 312, 318 , 154 P. 626, 628 (1916), for the proposition that, for the purpose of determining the applicable statute of limitations, a “statutory liability ... is one that depends for its existence on *395 the enactment of the statute and not on the contract of the parties.” Though the court recognized that this holding was not controlling in light of this Court’s finding in Kelso that the contracts incorporated the SIF’s statutory framework, the court explained that Dietrich supported its determination that the gravamen of th

2005The district court cited to Dietrich v. Copeland Lumber Co., 28 Idaho 312, 318 , 154 P. 626, 628 (1916), for the proposition that, for the purpose of determining the applicable statute of limitations, a “statutory liability ... is one that depends for its existence on *395 the enactment of the statute and not on the contract of the parties.” Though the court recognized that this holding was not controlling in light of this Court’s finding in Kelso that the contracts incorporated the SIF’s statutory framework, the court explained that Dietrich supported its determination that the gravamen of th

11
Aberdeen-Springfield Canal Co. v. Peipergreen
idaho · 1999 · cited in 1 Idaho opinions naming this issue, 2003–2003
2 sentences

2003THE STATE IS NOT UNJUSTLY ENRICHED BY THE COLLECTION OF THE TRANSFER FEE IMPOSED UNDER I.C. § 23-908(5) BHA argues that any portion of the transfer fee charged in excess of that which is necessary to enforce the regulation is an unjust enrichment for the State, outlining the elements of an unjust enrichment claim as set forth in Aberdeen-Springfield Canal Company v. Peiper, 133 Idaho 82, 88 , 982 P.2d 917, 923 (1999): (1) a benefit is conferred upon defendant by plaintiff, (2) appreciation by the defendant of the benefit, and (3) acceptance of the benefit under circumstances that would be ineq

2003THE STATE IS NOT UNJUSTLY ENRICHED BY THE COLLECTION OF THE TRANSFER FEE IMPOSED UNDER I.C. § 23-908(5) BHA argues that any portion of the transfer fee charged in excess of that which is necessary to enforce the regulation is an unjust enrichment for the State, outlining the elements of an unjust enrichment claim as set forth in Aberdeen-Springfield Canal Company v. Peiper, 133 Idaho 82, 88 , 982 P.2d 917, 923 (1999): (1) a benefit is conferred upon defendant by plaintiff, (2) appreciation by the defendant of the benefit, and (3) acceptance of the benefit under circumstances that would be ineq

11
Holmes v. Holmesgreen
idahoctapp · 1994 · cited in 1 Idaho opinions naming this issue, 1994–1994
2 sentences

1994I.R.C.P. 54(d)(1)(B); Holmes v. Holmes, 125 Idaho 784 , 874 P.2d 595, 599 (Ct.App.1994).

1994I.R.C.P. 54(d)(1)(B); Holmes v. Holmes, 125 Idaho 784 , 874 P.2d 595, 599 (Ct.App.1994).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Idaho. Read the followed side critically anyway.

Also cited on this issue (9)

CaseCitedYears
Stevenson v. Windermere Real Estate/Capital Group, Inc. green
idaho · 2012
2 sentences

2014Ultimately, we concluded that the Stevensons’ unjust enrichment claim against Windermere could not be maintained because Jefferson conferred the $9,500 benefit on Windermere and thus, it was “not a benefit that the Stevensons conferred on Windermere.” Id. at 829 , 275 P.3d at 844 .

2014Ultimately, we concluded that the Stevensons’ unjust enrichment claim against Windermere could not be maintained because Jefferson conferred the $9,500 benefit on Windermere and thus, it was “not a benefit that the Stevensons conferred on Windermere.” Id. at 829 , 275 P.3d at 844 .

22014–2014
Bates v. Seldin green
idaho · 2009
2 sentences

2025Only when the express agreement is enforceable is a court precluded from applying the equitable doctrine of unjust enrichment in contravention of the express contract. 13 Id. at 776–77, 203 P.3d at 706–07 (citations omitted).

2025Only when the express agreement is enforceable is a court precluded from applying the equitable doctrine of unjust enrichment in contravention of the express contract. 13 Id. at 776–77, 203 P.3d at 706–07 (citations omitted).

12025–2025
Haskin v. Glass green
idahoctapp · 1982
1 sentence

2021Id.

12021–2021
Terry Barr Sales Agency, Inc. v. All-Lock Company, Inc. green
ca6 · 1996
1 sentence

2011Ingram, 256 F.Supp.2d at 24 (quoting Terry Barr, 96 F.3d at 181 ).

12011–2011
Ingram v. Rencor Controls, Inc. green
med · 2003
1 sentence

2011Ingram, 256 F.Supp.2d at 24 (quoting Terry Barr, 96 F.3d at 181 ).

12011–2011
Blaser v. Cameron green
idahoctapp · 1991
2 sentences

2011Blaser, 121 Idaho at 1017 , 829 P.2d at 1366 .

2011Blaser, 121 Idaho at 1017 , 829 P.2d at 1366 .

12011–2011
Dale's Service Company, Inc. v. Jones green
idaho · 1975
2 sentences

1999In this regal’d, the district court misapplied Dale’s Service Co., Inc. v. Jones, 96 Idaho 662 , 534 P.2d 1102 (1975), and incorrectly created a distinction between an action for quantum meruit and unjust enrichment because both quantum meruit and unjust enrichment do involve claims based on an implicit promise to pay. 7 In Continental Forest Products, Inc. v. Chandler Supply Co., 95 Idaho 739 , 518 P.2d 1201 (1974), this Court recognized three types of contractual arrangements: First is the express contract wherein the parties expressly agree regarding a transaction.

1999In this regal’d, the district court misapplied Dale’s Service Co., Inc. v. Jones, 96 Idaho 662 , 534 P.2d 1102 (1975), and incorrectly created a distinction between an action for quantum meruit and unjust enrichment because both quantum meruit and unjust enrichment do involve claims based on an implicit promise to pay. 7 In Continental Forest Products, Inc. v. Chandler Supply Co., 95 Idaho 739 , 518 P.2d 1201 (1974), this Court recognized three types of contractual arrangements: First is the express contract wherein the parties expressly agree regarding a transaction.

11999–1999
Brown v. Yacht Club of Coeur D'Alene, Ltd. green
idahoctapp · 1986
1 sentence

1994The value of the benefits must be realized by the breaching party under circumstances where it would be inequitable to avoid payment. 111 Idaho at 199, 722 P.2d at 1066 .

11994–1994
Graves v. Cupic green
idaho · 1954
2 sentences

1984Hence, I mention only that it does seem that if Smith, Inc. is entitled to a commission on the in-lieu-of foreclosure out-of-court settlement, it might be hardpressed to establish a selling price where there was not a sale, per se, but a compromised dispute of the Knudsons' unjust enrichment claim as per Graves v. Cupic, 75 Idaho 451 , 272 P.2d 1020 (1954), and its progeny.

1984Hence, I mention only that it does seem that if Smith, Inc. is entitled to a commission on the in-lieu-of foreclosure out-of-court settlement, it might be hardpressed to establish a selling price where there was not a sale, per se, but a compromised dispute of the Knudsons' unjust enrichment claim as per Graves v. Cupic, 75 Idaho 451 , 272 P.2d 1020 (1954), and its progeny.

11984–1984

Statutes the citing opinions construe

ID § Idaho Code § 12-120 (14) ID § Idaho Code § 12-121 (12)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NY 265 (1942–2026) OH 143 (1986–2026) DE 101 (2001–2026) TX 76 (1991–2026) IL 75 (1957–2026) PA 69 (1956–2026) MI 65 (1975–2026) CT 61 (1968–2026) NC 53 (1952–2026) WA 53 (1941–2026) ME 49 (1974–2024) CA 46 (1950–2026) WI 44 (1975–2026) CO 42 (1989–2026) LA 39 (1965–2023) VT 36 (1914–2026) MD 35 (1958–2025) FL 34 (1953–2025) AZ 33 (1989–2026) UT 31 (1999–2025) MO 30 (1998–2023) MN 29 (1989–2026) TN 29 (1975–2026) GA 28 (1987–2026) NJ 27 (1984–2026) ID 23 (1984–2026) OR 23 (1977–2025) AL 22 (2000–2025) AR 21 (1955–2023) MT 19 (1967–2024) NM 19 (1990–2024) IA 18 (1939–2025) ND 16 (1974–2026) MA 14 (2010–2026) WY 14 (1989–2026) NV 12 (2014–2022) OK 10 (1935–2024) IN 10 (1971–2026) RI 10 (1969–2016) KS 9 (1996–2024) NE 9 (2015–2024) DC 8 (2005–2025) SC 7 (2002–2025) MS 7 (1998–2013) VA 7 (1992–2024) KY 7 (1929–2023) WV 6 (1988–2020) NH 6 (1982–2018) SD 5 (1991–2025) HI 4 (2013–2025) VI 3 (2013–2014) AK 2 (1996–2002)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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