Legal Memorandum: Unjust Enrichment Claims in MN

Issue: What elements are necessary to establish an unjust enrichment claim.

To establish an unjust enrichment claim, the claimant must show that the defendant has knowingly received or obtained something of value for which the defendant in equity and good conscience should pay.  ServiceMaster of St. Cloud v. GAB Bus. Servs. Inc., 542 N.W.2d 302, 306 (Minn. 1996).

In addition “[t]he existence of a valid contract, by itself, does not foreclose a claim for unjust enrichment.”  Lyon Fin. Servs., Inc. v. MBS Mgmt. Servs., Inc., No.06-4562 (PJS-JJS) (D. Minn. Sept. 27, 2007) (J. Schiltz).  Thus, for example, “if a contract is valid, but the rights of the parties are ambiguous, the remedy of unjust enrichment remains available.”  Id. (citing Midwest Sports Mkt’g, Inc., 552 N.W.2d at 268).  See also Christopher v. Hanson, No. 09-3703 (JNE/JJK) (D. Minn. June 6, 2011) (where “Plaintiffs ask for relief [i.e. unjust enrichment] based on rights not governed by the contracts . . . the Court cannot conclude, at the summary judgment stage, that there are valid contracts governing the rights of the parties.”); Midwest Sports Mkt’g, Inc., 552 N.W.2d at 268 (although “equitable relief cannot be granted where the rights of the parties are governed by a valid contract [but] [e]ven so, if the contract is not a full agreement concerning the details of compensation, a party may recover on an unjust enrichment claim”).  

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