Feagin v. Jackson
2012 Ark. App. 306
| Ark. Ct. App. | 2012Background
- Feagin paid the full purchase price for Lots 5–7 in Southern Hills Estates; title was taken in both names as joint tenants with right of survivorship.
- After Lot 7 sold for $37,000, proceeds were to be allocated; Stephanie retained mineral rights for Lot 7; the relationship ended in late 2009.
- Stephanie sued Shawn to reform the deed to remove his joint tenancy and to recover $30,000 she loaned him in January 2009; Shawn counterclaimed for partition of the remaining lots.
- In January 2010 Stephanie amended to acknowledge no mistake in the joint title and that Shawn had no equitable interest.
- The bench trial in June 2010 found both parties held a one-half interest, ordered sale of the lots and division of proceeds, denied unjust enrichment, and deducted $30,000 from Shawn’s share; the court entered a final order under Rule 54(b).
- On appeal, the Arkansas Court of Appeals affirmed the trial court’s rulings on direct appeal and cross-appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether unjust enrichment was proven. | Feagin contends Shawn’s retention of half the proceeds would unjustly enrich him. | Jackson contends no unjust enrichment occurred given the joint title and labor contributions. | affirmed; trial court’s finding not clearly erroneous. |
| Whether the $30,000 loan was extinguished by accord and satisfaction. | Feagin argues the loan was not settled by Lot 7 proceeds. | Jackson argues accord and satisfaction extinguished the debt. | affirmed; trial court did not credit accord and satisfaction. |
| Whether the partition proceeds were properly allocated between the joint tenants. | Feagin asserts her entitlement to recovery consistent with ownership and unjust enrichment argument. | Jackson asserts equal division of proceeds as co-owners. | affirmed; trial court’s distribution based on equal half-interestFinding. |
Key Cases Cited
- Grisanti v. Zanone, 2010 Ark. App. 545 (Ark. App. 2010) (unjust enrichment requires value received and unfair retention)
- Campbell v. Asbury Auto., Inc., 2011 Ark. 157 (Ark. 2011) (unjust enrichment involves absence of contract or exceptional circumstances)
- Le v. Nguyen, 2010 Ark. App. 712 (Ark. App. 2010) (equitable principle to render fair outcomes)
- Baumgartner v. Rogers, 233 Ark. 387 (1961) (burden of proving contract defense like unjust enrichment)
- Sims v. Moser, 373 Ark. 491 (2008) (review of bench-trial findings; clearly erroneous standard)