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

18 Iowa opinions name it 2 courts 1939–2025 6 in the last five years

The cases below were cited by Iowa 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 (17)

CaseFollowedCited
Johnson v. Dodgengreen
iowa · 1990 · cited in 3 Iowa opinions naming this issue, 2000–2023
2 sentences

2023And, “[g]enerally[,] the existence of a contract precludes the application of the doctrine of unjust enrichment.” Johnson v. Dodgen, 451 N.W.2d 168, 175 (Iowa 1990); see also Kunde, 920 N.W.2d at 807 (“The existence of an express contract on these matters prevents [the plaintiff] from circumventing their agreement by seeking to use [the theory] of unjust enrichment . . . to recover . . . .”).

2022And, “[g]enerally[,] the existence of a contract precludes the application of the doctrine of unjust enrichment.” Johnson v. Dodgen, 451 N.W.2d 168, 176 (Iowa 1990); see also Kunde, 920 N.W.2d at 807 (“The existence of an express contract on these matters prevents [the plaintiff] from circumventing their agreement by seeking to use [the theory] of unjust enrichment . . . to recover.”).

33
Ronald Dwight Kunde v. Estate of Arthur D. Bowman and Diane Engelkinsgreen
iowa · 2018 · cited in 3 Iowa opinions naming this issue, 2019–2023
2 sentences

2023And, “[g]enerally[,] the existence of a contract precludes the application of the doctrine of unjust enrichment.” Johnson v. Dodgen, 451 N.W.2d 168, 175 (Iowa 1990); see also Kunde, 920 N.W.2d at 807 (“The existence of an express contract on these matters prevents [the plaintiff] from circumventing their agreement by seeking to use [the theory] of unjust enrichment . . . to recover . . . .”).

2022And, “[g]enerally[,] the existence of a contract precludes the application of the doctrine of unjust enrichment.” Johnson v. Dodgen, 451 N.W.2d 168, 176 (Iowa 1990); see also Kunde, 920 N.W.2d at 807 (“The existence of an express contract on these matters prevents [the plaintiff] from circumventing their agreement by seeking to use [the theory] of unjust enrichment . . . to recover.”).

33
Meyer v. Gotsdinergreen
iowa · 1929 · cited in 2 Iowa opinions naming this issue, 2018–2018
2 sentences

2018See Meyer, 208 Iowa at 681 , 226 N.W. at 39 .

2018See Meyer, 208 Iowa at 681 , 226 N.W. at 39 .

22
Smith v. Harrisongreen
iowa · 1982 · cited in 2 Iowa opinions naming this issue, 1990–2021
2 sentences

2021In Smith v. Harrison, we analyzed an unjust enrichment claim in circumstances where a tenant (Harrison) received benefits from a discounted rental rate on a farm lease with a landlord who shortly thereafter became the ward in a conservatorship. 325 N.W.2d at 94 .

1990Smith v. Harrison, 325 N.W.2d 92, 94 (Iowa 1982); 66 Am.Jur.2d Restitution and Implied Contracts, § 6 at 949 (1973).

12
Riecks v. Independent School Districtgreen
iowa · 1934 · cited in 2 Iowa opinions naming this issue, 1939–1939
2 sentences

1939In the language of the trial court "the fundamental question involved in this case is whether where a governmental agency is charged with a mandatory governmental duty, may any one who is deemed to have that duty owing to him, after making demand upon such agency for the performance thereof, then proceed to perform such governmental function and then sue such agency at law for the reasonable cost of performing the same, or whether such person so aggrieved by such refusal is confined to the remedy of mandamus." In Riecks v. Independent School District, 219 Iowa 101 , 104 , 106 , 257 N.W. 546 ,

1939In the language of the trial court "the fundamental question involved in this case is whether where a governmental agency is charged with a mandatory governmental duty, may any one who is deemed to have that duty owing to him, after making demand upon such agency for the performance thereof, then proceed to perform such governmental function and then sue such agency at law for the reasonable cost of performing the same, or whether such person so aggrieved by such refusal is confined to the remedy of mandamus." In Riecks v. Independent School District, 219 Iowa 101 , 104 , 106 , 257 N.W. 546 ,

12
Passehl Estate v. Passehlgreen
iowa · 2006 · cited in 1 Iowa opinions naming this issue, 2025–2025
1 sentence

2025See Passehl Est. v. Passehl, 712 N.W.2d 408 , 414 n.6 (Iowa 2006).

11
Dolezal v. City of Cedar Rapidsgreen
iowa · 1982 · cited in 1 Iowa opinions naming this issue, 2023–2023
1 sentence

2023See Dolezal v. City of Cedar Rapids, 326 N.W.2d 355, 360 (Iowa 1982) (finding that unjust enrichment claims fall under the five-year statute of limitations).

11
Sanford v. Lucegreen
iowa · 1953 · cited in 1 Iowa opinions naming this issue, 2023–2023
1 sentence

2023Citing Sanford v. Luce, the district court determined that because the building construction was ongoing through 2020 and because the statute of limitations did not accrue until the building was completed, the unjust enrichment claim was not time-barred. 60 N.W.2d 885, 886 (Iowa 1953) (finding when the defendant agreed to pay upon completion of the construction, the cause of action would accrue upon completion of plaintiff’s performance of his part of the agreement); Foley v. City of Cedar Rapids, 110 N.W. 158 , 160–61 (Iowa 1907).

11
Evans Products Co. v. Jorgensengreen
or · 1966 · cited in 1 Iowa opinions naming this issue, 2020–2020
1 sentence

2020Co. v. Jorgensen, 421 P.2d 978, 983 (Or. 1966) (en banc) (“The purpose and effectiveness of the UCC would be substantially impaired if interests created in compliance with UCC procedures could be defeated by application of the equitable doctrine of unjust enrichment.”); Peerless Packing Co. v. Malone & Hyde, Inc., 376 S.E.2d 161 , 164 n.4 (W.

11
Peerless Packing Co. v. Malone & Hyde, Inc.green
wva · 1988 · cited in 1 Iowa opinions naming this issue, 2020–2020
1 sentence

2020Co. v. Jorgensen, 421 P.2d 978, 983 (Or. 1966) (en banc) (“The purpose and effectiveness of the UCC would be substantially impaired if interests created in compliance with UCC procedures could be defeated by application of the equitable doctrine of unjust enrichment.”); Peerless Packing Co. v. Malone & Hyde, Inc., 376 S.E.2d 161 , 164 n.4 (W.

11
Darla Legg and Jason T. Legg, on Behalf of Themselves and All Persons Similarly Situated v. West Bankgreen
iowa · 2016 · cited in 1 Iowa opinions naming this issue, 2020–2020
1 sentence

2020Bank, 873 N.W.2d 763, 771 (Iowa 2016) (quoting Ahrendsen ex rel.

11
Larsen v. Warringtongreen
iowactapp · 1984 · cited in 1 Iowa opinions naming this issue, 2020–2020
1 sentence

2020Larsen v. Warrington, 348 N.W.2d 637, 643 (Iowa Ct. App. 1984), overruled in part on other grounds by C & H Farm Serv.

11
Chenery v. Agri-Lines Corp.green
idaho · 1988 · cited in 1 Iowa opinions naming this issue, 2001–2001
1 sentence

2001See Oregon Laborers-Employers Health & Welfare Trust Fund v. Phillip Morris Inc., 185 F.3d 957, 968 (9th Cir.1999) (plaintiff to an unjust enrichment claim does not provide a benefit to the defendant by paying bills of third parties which the defendant had no legal obligation to pay); Chenery, 766 P.2d at 755 (claim for subrogation requires that a party making a payment to a third party must have an obligation to make that payment or a recognizable interest to protect); Shonka v. Campbell, 260 Iowa 1178, 1182 , 152 N.W.2d 242, 245 (1967) (a claim for contribution requires that the injured part

11
Plan v. Philip Morris Incorporatedgreen
ca9 · 1999 · cited in 1 Iowa opinions naming this issue, 2001–2001
1 sentence

2001See Oregon Laborers-Employers Health & Welfare Trust Fund v. Phillip Morris Inc., 185 F.3d 957, 968 (9th Cir.1999) (plaintiff to an unjust enrichment claim does not provide a benefit to the defendant by paying bills of third parties which the defendant had no legal obligation to pay); Chenery, 766 P.2d at 755 (claim for subrogation requires that a party making a payment to a third party must have an obligation to make that payment or a recognizable interest to protect); Shonka v. Campbell, 260 Iowa 1178, 1182 , 152 N.W.2d 242, 245 (1967) (a claim for contribution requires that the injured part

11
Shonka v. Campbellgreen
iowa · 1967 · cited in 1 Iowa opinions naming this issue, 2001–2001
2 sentences

2001See Oregon Laborers-Employers Health & Welfare Trust Fund v. Phillip Morris Inc., 185 F.3d 957, 968 (9th Cir.1999) (plaintiff to an unjust enrichment claim does not provide a benefit to the defendant by paying bills of third parties which the defendant had no legal obligation to pay); Chenery, 766 P.2d at 755 (claim for subrogation requires that a party making a payment to a third party must have an obligation to make that payment or a recognizable interest to protect); Shonka v. Campbell, 260 Iowa 1178, 1182 , 152 N.W.2d 242, 245 (1967) (a claim for contribution requires that the injured part

2001See Oregon Laborers-Employers Health & Welfare Trust Fund v. Phillip Morris Inc., 185 F.3d 957, 968 (9th Cir.1999) (plaintiff to an unjust enrichment claim does not provide a benefit to the defendant by paying bills of third parties which the defendant had no legal obligation to pay); Chenery, 766 P.2d at 755 (claim for subrogation requires that a party making a payment to a third party must have an obligation to make that payment or a recognizable interest to protect); Shonka v. Campbell, 260 Iowa 1178, 1182 , 152 N.W.2d 242, 245 (1967) (a claim for contribution requires that the injured part

11
Shadle v. Borruschgreen
iowa · 1963 · cited in 1 Iowa opinions naming this issue, 1966–1966
2 sentences

1966R.2d 982; Shadle v. Borrusch, 255 Iowa 1122, 1126, 1127 , 125 N.W.2d 507, 510 ; Smith v. Stowell, 256 Iowa 165, 173 , 125 N.W.2d 795, 799, 800 .

1966R.2d 982; Shadle v. Borrusch, 255 Iowa 1122, 1126, 1127 , 125 N.W.2d 507, 510 ; Smith v. Stowell, 256 Iowa 165, 173 , 125 N.W.2d 795, 799, 800 .

11
Smith v. Stowellgreen
iowa · 1964 · cited in 1 Iowa opinions naming this issue, 1966–1966
2 sentences

1966R.2d 982; Shadle v. Borrusch, 255 Iowa 1122, 1126, 1127 , 125 N.W.2d 507, 510 ; Smith v. Stowell, 256 Iowa 165, 173 , 125 N.W.2d 795, 799, 800 .

1966R.2d 982; Shadle v. Borrusch, 255 Iowa 1122, 1126, 1127 , 125 N.W.2d 507, 510 ; Smith v. Stowell, 256 Iowa 165, 173 , 125 N.W.2d 795, 799, 800 .

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (7)

CaseCitedYears
Jordan v. St. John's Mercy Medical Center green
moctapp · 2013
2 sentences

2018Similarly, in Damon v. City of Kansas City, another Missouri appellate court considered a case where the trial court granted a motion 92 to dismiss an unjust enrichment claim in an ATE case. 419 S.W.3d 162 , 194 (Mo. Ct. App. 2013).

2018Similarly, in Damon v. City of Kansas City, another Missouri appellate court considered a case where the trial court granted a motion 92 to dismiss an unjust enrichment claim in an ATE case. 419 S.W.3d 162 , 194 (Mo. Ct. App. 2013).

22018–2018
Brunner v. City of Arnold green
moctapp · 2013
2 sentences

2018In Brunner v. City of Arnold, the appellate court determined there might have been sufficient duress to avoid application of the voluntary payment doctrine. 427 S.W.3d 201 , 235–36 (Mo. Ct. App. 2013), overruled in part on other grounds in Tupper v. City of St.

2018In Brunner v. City of Arnold, the appellate court determined there might have been sufficient duress to avoid application of the voluntary payment doctrine. 427 S.W.3d 201 , 235–36 (Mo. Ct. App. 2013), overruled in part on other grounds in Tupper v. City of St.

22018–2018
Myron Dennis Behm, Burton J. Brooks, Bobby Lee Langston, David Leon Brodsky, Jeffrey R. Olson, and Geoff Tate Smith v. City of Cedar Rapids and Gatso USA, Inc. green
iowa · 2019
1 sentence

2023To prove an unjust enrichment claim, a party must show: “(1) enrichment of the defendant, (2) at the expense of the plaintiff, (3) under circumstances that make it unjust for the defendant to retain the benefit.” Id. (quoting Behm, 922 N.W.2d at 577 ).

12023–2023
Foley v. City of Cedar Rapids green
· 1907
1 sentence

2023Citing Sanford v. Luce, the district court determined that because the building construction was ongoing through 2020 and because the statute of limitations did not accrue until the building was completed, the unjust enrichment claim was not time-barred. 60 N.W.2d 885, 886 (Iowa 1953) (finding when the defendant agreed to pay upon completion of the construction, the cause of action would accrue upon completion of plaintiff’s performance of his part of the agreement); Foley v. City of Cedar Rapids, 110 N.W. 158 , 160–61 (Iowa 1907).

12023–2023
Iowa Waste Systems, Inc. v. Buchanan County green
iowactapp · 2000
1 sentence

2020Id.

12020–2020
Executors of the Estate of Peck v. Peck green
iowa · 1993
1 sentence

1998We found no “injustice” in the husband’s continued ownership of marital assets, noting that “[i]f mere wishes or expectations of a party may provide the basis for an unjust enrichment claim, the potential for using constructive trusts is virtually unlimited.” Id.

11998–1998
Gard v. Razanskas green
iowa · 1957
2 sentences

1966We have recently considered the doctrine of unjust enrichment in Gard v. Razanskas, 248 Iowa 1333, 1336 , 85 N.W.2d 612, 614 , 65 A. L.

1966We have recently considered the doctrine of unjust enrichment in Gard v. Razanskas, 248 Iowa 1333, 1336 , 85 N.W.2d 612, 614 , 65 A. L.

11966–1966

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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