Spolar v. Spolar Fam. Trust, Pa. Super. LEXIS 476 2024 (Pa. Superior Ct., November 1, 2024)(Panella, J.)
The trial court’s factual findings are supported by the record, which established Mother actively encouraged Daughter to build her home on the 20-acre parcel and held out her Daughter as the owner of the home. As the injury was not inflicted until June of 2018, and Appellees filed suit approximately a month later, Appellants’ first claim of error fails.
Appellants next argue the trial court erred in finding they were unjustly enriched because “Appellees clearly received a significant benefit for over 35 years [because Daughter was permitted to live on the property rent-free].”
Unjust enrichment describes recovery for the value of the benefit retained when there is no contractual relationship, but when, on the grounds of fairness and justice, the law compels performance of a legal and moral duty to pay. We have further defined unjust enrichment as the defendant either wrongfully secured or passively received a benefit that would be unconscionable for her to retain.
The trial court did not err in making this determination. Appellants’ claim that Appellees were permitted to live rent-free and therefore received their own benefit of the arrangement flies in the face of logic. Daughter never would have built the home on Mother’s land if Daughter did not believe she owned the home. Daughter produced many receipts and photographs at trial that showed her progression of clearing the lot, installing electric, building the septic, drilling the well, and the construction of the home.
• Daughter claimed mother was unjustly enriched because she made improvements to the property, and that mother claimed daughter did not own the property.
• Statute of limitations is four years.
• Trial court’s findings are supported that the injury was inflicted until June of 2018, and suit was filed within the statute of limitations.
• Injury was inflicted when mother attempted to evict her daughter.
• Unjust enrichment applies in the case of which the daughter made tremendous improvements to the property.
