Derrick v. Derrick, 2015 Ark. App. 272

Bob Derrick moved in with his mother, Juanita, in 2006 and built a new house and landscaping on Juanita’s Greenwood property, spending over $600,000.
Juanita had conveyed remainder interests in the property to her grandchildren Sara and John in 1995 (joint tenants); they converted to tenancy in common in 2006; Juanita retained a life estate.
After construction, Bob sued Juanita, Sara, and John seeking an interest in or lien on the property for unjust enrichment.
Juanita’s answer acknowledged an understanding that Bob would be compensated for improvements, either by money or land; Sara and John denied entitlement and counterclaimed for ejectment/trespass and destruction/removal of property.
At the bench trial, the court orally granted Bob’s motion for directed verdict on Sara and John’s counterclaims but later entered a written judgment dismissing Bob’s unjust-enrichment claim without mentioning the oral dismissal of the counterclaims.
Bob appealed; the Court of Appeals dismissed the appeal for lack of a final, appealable order because the written judgment did not dispose of the counterclaims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Bob proved unjust enrichment warranting an interest or lien	Bob argued his expenditures on the property unjustly enriched Juanita, Sara, and John	Juanita, Sara, and John contended Bob failed to show entitlement; Juanita asserted prior agreement about compensation	Court’s written judgment found Bob failed to establish unjust enrichment (but appeal dismissed for other reason)
Whether the appellate court may review trial judgment absent written disposition of counterclaims	Bob argued the trial court orally dismissed counterclaims and appeal should proceed	Appellees and rules require written order; oral bench rulings are not effective until reduced to writing	Appeal dismissed for lack of jurisdiction because judgment omitted written disposition of counterclaims

Bevans v. Deutsche Bank Nat’l Trust Co., 373 Ark. 105 (explaining appeals lie only from final judgments)
Nat’l Home Ctrs., Inc. v. Coleman, 370 Ark. 119 (oral bench orders are ineffective until reduced to written, controlling order)