Legal Memorandum: Summary Judgment for an Unjust Enrichment Claim

Issue: Under Minnesota law, when is summary judgment appropriate in a claim for unjust enrichment?

           Courts must construe pleadings in a manner that promotes “substantial justice.”  Minn. R. Civ. P. 8.06.  To further this goal courts should interpret pleadings liberally in favor of the pleader and judge them by their substance not their form.  Basich v. Board of Pensions, 493 N.W.2d 293, 295 (Minn. Ct. App. 1992). 

A complaint need not label each legal theory which supports a plaintiff’s claims for recovery.  See Minn. R. Civ. R. 8.01, 8.05(a).

Because technical forms of action have been abolished, the label for or nature of a cause of action is determined by the facts alleged, not by the formal character of the complaint.  Walsh v. Mankato Oil Co., 201 Minn. 58, 275 N.W. 377, 380 (1937) (it is unnecessary and improper to label a complaint to characterize it).

A complaint, therefore, need not expressly allege legal theories or conclusions but need only give fair notice of the incident giving rise to the claim with sufficient clarity to disclose a viable theory.  Basich, 493 N.W.2d at 295.  For more than sixty years the test has been whether the facts alleged, liberally construed, entitle the plaintiff to any relief, either legal or equitable, though the plaintiff may have misconceived the nature of his cause or may have demanded inappropriate relief.  Lucas v. Medical Arts Bldg. Co., 207 Minn. 380, 291 N.W. 892 (1939); Smith v. Smith, 204 Minn. […]