Turcott v. Estate of Clarence D. Bates: Unjust Enrichment and How to Avoid It

The Idaho Supreme Court recently affirmed a court’s award of damages for unjust enrichment. The case, Turcott v. Estate of Clarence D. Bates, concerned a woman and her husband who spent a substantial amount of time and money making improvements for the woman’s father with the assumption that the woman would inherit half of the father’s estate.


The father, however, changed his will and decided to leave nothing to his daughter. As a result, the daughter filed a lawsuit seeking compensation for the work that she performed. The district court subsequently determined that there was not any implied in fact contract between the woman and her father. The court, however, awarded damages under a theory of unjust enrichment.


This article takes a brief look at unjust enrichment claims in New York state as well as the various defenses that can be raised in response to these claims.


The Elements of an Unjust Enrichment Claim


To establish an unjust enrichment claim in New York, there are several elements that must be shown.


New York courts have provided some substantial guidance in this area and repeatedly stated that to prove unjust enrichment, a person must show that a benefit was given to a person and that the person received this benefit without adequately compensating the person who provided the service.


How Unjust Enrichment is Different from Other Claims


Unjust enrichment is distinct from many other types of claims.


New York courts have established that unjust enrichment merely requires showing that a party benefitted at someone’s expense and that equity and good conscience require restitution.


The doctrine of unjust enrichment is available whether a party has obtained money by wrongdoing, an illegal act, or a mistake.


Sometimes, unjust enrichment claims can exist even if a person did not intend to injure a party.

Another aspect of unjust enrichment claims that is important to understand is that claims only exist when there is not an enforceable contract between the two parties. This means that a person cannot have a claim for both breach of contract as well as unjust enrichment.


If a party raises both claims of a contractual relationship and unjust enrichment, a court is required to dismiss either one or both of the claims.


Defenses to Unjust Enrichment Claims


There are several defenses that can be raised in response to an unjust enrichment claim. These defenses include:


  • The person pursuing the unjust enrichment claim should not receive restitution because they acted in bad faith or unethically
  • Fraud was part of providing the services
  • A valid contract addresses each party’s rights and obligations concerning the benefit that was received
  • The relationship between the parties was “too attenuated” and was not close in nature


As a result, to make the strong unjust enrichment claim possible, it is often a good idea to obtain the assistance of a skilled attorney.


Speak with an Experienced Estate Planning Lawyer


To make sure that your estate planning goals are fully carried out, it can help to speak with an experienced estate planning lawyer.

Contact Ettinger Estate Planning today to schedule a free initial case evaluation.

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