Cressy v. Proctor, 666 F. App'x 70

Ronald Cressy and Kevin Proctor were domestic partners; Cressy performed full-time administrative and clerical work running day-to-day operations for Proctor’s business, Synergy, from mid‑1994 through February 2008.
Cressy received no paycheck; instead he enjoyed household/lifestyle benefits from the domestic relationship.
After the relationship ended and Synergy closed, Cressy sought equitable restitution (quantum meruit) for the reasonable value of his labor.
The District of Vermont conducted a bench trial, found Cressy’s labor materially benefitted Proctor, and awarded $107,957 based on a $40,000 starting salary in 1994 with growth through 2008.
Proctor appealed, arguing the award was legally improper, that laches/estoppel barred recovery, that lifestyle benefits should offset damages, and that the damages period and salary baseline were incorrect.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether quantum meruit restitution is appropriate for unpaid services performed during a domestic relationship	Cressy: His full‑time, business‑level labor conferred a material benefit warranting restitution measured by reasonable value of services	Proctor: Services were part of domestic exchange; lifestyle benefits already compensated Cressy, so no restitution owed	Court: Affirmed award of quantum meruit; labor was distinct from normal domestic benefits and materially benefitted Proctor
Standard of review for awarding equitable restitution	Cressy: District court’s equitable award reviewed for abuse of discretion	Proctor: Argued de novo review should apply	Court: Review is abuse of discretion; fact findings reviewed for clear error
Laches / estoppel defenses	Cressy: Delay in asserting claim was reasonable given ongoing domestic relationship	Proctor: Cressy waited unreasonably and acquiesced, so barred	Court: Rejected laches and estoppel; no unreasonable delay or prejudice because claim accrues on dissolution
Computation of damages (earning period, salary baseline, offsets)	Cressy: Use full‑time employment period (mid‑1994–Feb 2008), $40,000 starting salary with growth; no offset for domestic benefits	Proctor: Limit period, use $30,000 starting salary, and offset value of lifestyle benefits after 2008	Court: Calculations accepted; earnings period and $40,000 baseline supported by evidence; no offset for normal domestic benefits

Amara v. Cigna Corp., 775 F.3d 510 (2d Cir. 2014) (equitable relief reviewed for abuse of discretion and factual findings for clear error)
Weed v. Weed, 968 A.2d 310 (Vt. 2008) (equitable remedies reviewed for abuse of discretion)
Harman v. Rogers, 510 A.2d 161 (Vt. 1986) (unmarried partner’s uncompensated business services held to materially benefit owner; restitution ordered)
DJ Painting, Inc. v. Baraw Enters., Inc., 776 A.2d 413 (Vt. 2001) (equitable restitution based on implied promise when retention of benefit is inequitable)
United States v. Murphy, 703 F.3d 182 (2d Cir. 2012) (factfinder’s permissible choice among competing views of evidence not clearly erroneous)