unjust enrichment claim (District of Columbia) · Go Syfert
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unjust enrichment claim in District of Columbia

8 District of Columbia opinions name it 1 courts 2005–2025 2 in the last five years

The cases below were cited by District of Columbia 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 (7)

CaseFollowedCited
News World Communications, Inc. v. Thompsengreen
dc · 2005 · cited in 5 District of Columbia opinions naming this issue, 2016–2025
2 sentences

2025We agree. 21 For statute of limitation purposes, an unjust enrichment claim accrues “when the plaintiff’s last service has been rendered and compensation has been wrongfully withheld.” News World Commc’ns, Inc. v. Thompsen, 878 A.2d 1218, 1219 (D.C. 2005).

2021The elements of an unjust enrichment claim are that “(1) the plaintiff conferred a benefit on the defendant; (2) the defendant retains the benefit; and (3) under the circumstances, the defendant’s retention of the benefit is unjust.” News World Comms., Inc. v. Thompson, 878 A.2d 1218, 1222 (D.C. 2005).

55
Chevalier v. Moongreen
dc · 1990 · cited in 2 District of Columbia opinions naming this issue, 2016–2016
2 sentences

2016Chevalier v. Moon, 576 A.2d 722, 724 (D.C. 1990) (quoting Garrett v. Washington Air Compressor Co., 466 A.2d 462 , 464 n.5 (D.C. 1983)). 10 F. Unjust Enrichment/Restitution The doctrine of unjust enrichment applies “when a person retains a benefit (usually money) which in justice and equity belongs to another.” Jordan Keys & Jessamy, LLP v. St.

2016Chevalier v. Moon, 576 A.2d 722, 724 (D.C. 1990) (quoting Garrett v. Washington Air Compressor Co., 466 A.2d 462 , 464 n.5 (D.C. 1983)). 10 F. Unjust Enrichment/Restitution The doctrine of unjust enrichment applies “when a person retains a benefit (usually money) which in justice and equity belongs to another.” Jordan Keys & Jessamy, LLP v. St.

22
MAIA FALCONI-SACHS v. LPF SENATE SQUARE, LLCgreen
dc · 2016 · cited in 2 District of Columbia opinions naming this issue, 2018–2021
2 sentences

2021Unjust enrichment occurs “when a person retains a benefit (usually money) which in justice and equity belongs to another.” Falconi-Sachs v. LPF Senate Square, LLC, 142 A.3d 550, 556 (D.C. 2016) (quoting Jordan Keys & Jessamy, LLP v. St.

2021Glasgow is thus incorrect to maintain that an unjust enrichment claim was inconsistent with the jury’s verdict; it was harmonious with it. 2 2 Glasgow argues that our decision in Falconi-Sachs, 142 A.3d at 556 , permits a trial court to entertain unjust enrichment only where it first finds an alleged contract invalid or unenforceable.

12
Campbell v. National Union Fire Insurance Company of Pittsburgh, Pagreen
dcd · 2015 · cited in 1 District of Columbia opinions naming this issue, 2021–2021
1 sentence

2021Co. of Pittsburgh, 130 F. Supp. 3d 236, 256 (D.D.C. 2015) (“[A] number of decisions from this Court have expressly held that a benefit indirectly conferred on a defendant can support an unjust enrichment claim.”) (collecting cases).

11
Jordan Keys & Jessamy, LLP v. St. Paul Fire & Marine Insurancegreen
dc · 2005 · cited in 1 District of Columbia opinions naming this issue, 2017–2017
2 sentences

2017Co., 870 A.2d 58, 63 (D.C. 2005).10 The limitations period for an unjust enrichment claim begins to run “when the . . . last service has been rendered and compensation has been wrongfully withheld.” News World Commc’ns, Inc., 878 A.2d at 1219 (emphasis added); id. at 1223 (citing Baer v. Chase in support of application of the last rendition of services test).

2017Co., 870 A.2d 58, 63 (D.C. 2005). 10 The limitations period for an unjust enrichment claim begins to run “when the .;.. last service has been rendered and compensation has been wrongfully withheld.'” News World Commc’ns, Inc., 878 A.2d at 1219 (emphasis added); id. at 1223 (citing Baer v. Chase in support of application of the last rendition of services test).

11
Robert v. Baer v. David Chase Chase Films Inc., a Delaware Corporation John Does A-Zgreen
ca3 · 2004 · cited in 1 District of Columbia opinions naming this issue, 2017–2017
2 sentences

2017Cf. Baer v. Chase, 392 F.3d 609, 622-23 (3d Cir. 2004).

2017Cf. Baer v. Chase, 392 F.3d 609, 622-23 (3d Cir. 2004).

11
Rabinowitz v. Massachusetts Bonding & Insurancegreen
nj · 1938 · cited in 1 District of Columbia opinions naming this issue, 2005–2005
2 sentences

2005Thus, in Rabinowitz v. Mass. Bonding & Insurance Co., 119 N.J.L. 552 , 197 A. 44, 47 ([NJ.Err. & App.]1938), the court used a last “rendition of services” calculation in an unjust enrichment claim.

2005Thus, in Rabinowitz v. Mass. Bonding & Insurance Co., 119 N.J.L. 552 , 197 A. 44, 47 ([NJ.Err. & App.]1938), the court used a last “rendition of services” calculation in an unjust enrichment claim.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (4)

CaseCitedYears
Garrett v. Washington Air Compressor Co., Inc. green
dc · 1983
2 sentences

2016Chevalier v. Moon, 576 A.2d 722, 724 (D.C. 1990) (quoting Garrett v. Washington Air Compressor Co., 466 A.2d 462 , 464 n.5 (D.C. 1983)). 10 F. Unjust Enrichment/Restitution The doctrine of unjust enrichment applies “when a person retains a benefit (usually money) which in justice and equity belongs to another.” Jordan Keys & Jessamy, LLP v. St.

2016Chevalier v. Moon, 576 A.2d 722, 724 (D.C. 1990) (quoting Garrett v. Washington Air Compressor Co., 466 A.2d 462 , 464 n.5 (D.C. 1983)). 10 F. Unjust Enrichment/Restitution The doctrine of unjust enrichment applies “when a person retains a benefit (usually money) which in justice and equity belongs to another.” Jordan Keys & Jessamy, LLP v. St.

22016–2016
Euclid Street, LLC v. District of Columbia Water & Sewer Authority green
dc · 2012
1 sentence

2015Indeed, we find we cannot, because timely notice under the statute is tied to injury, see supra note 29, and, as explained above, we cannot identify an injury traceable to the District. 31 .An unjust enrichment claim requires the plaintiff to demonstrate that "(1) the plaintiff conferred a benefit on the defendant; (2) the defendant retains the benefit; and (3) under *48 the circumstances, the defendant's retention of the benefit is unjust.” Euclid St., LLC v. District of Columbia Water & Sewer Auth., 41 A.3d 453 , 463 n. 10 (D.C.2012) (internal quotation marks omitted).

12015–2015
Kopin v. Orange Products, Inc. green
njsuperctappdiv · 1997
1 sentence

2005Additionally, the court in Kopin [v. Orange Prods., Inc.], 297 N.J.Super. 353 , 688 A.2d [130], 140 [(N.J.Super.A.D.1997)], cited a New York case granting summary judgment predicated on the statute of limitations in a quantum meruit case in which there was a failure of proof as to when the plaintiff completed his performance, Wint v. Fields, 177 A.D.2d 425 , 576 N.Y.S.2d 266 (N.Y.App.Div.1991).

12005–2005
Stockton v. Gristedes Supermarkets, Inc. neutral
nyappdiv · 1991
1 sentence

2005Additionally, the court in Kopin [v. Orange Prods., Inc.], 297 N.J.Super. 353 , 688 A.2d [130], 140 [(N.J.Super.A.D.1997)], cited a New York case granting summary judgment predicated on the statute of limitations in a quantum meruit case in which there was a failure of proof as to when the plaintiff completed his performance, Wint v. Fields, 177 A.D.2d 425 , 576 N.Y.S.2d 266 (N.Y.App.Div.1991).

12005–2005

Statutes the citing opinions construe

DC § D.C. Code § 12-301 (3)

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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