Haroldson v. Haroldson
2012 ND 44
| N.D. | 2012Background
- Dregseth appeals district court dismissal of his equitable claims against Brown in the Capital Harvest dispute.
- Case originated from 2005 suit alleging ownership interest promised by Brown; Erickson and Ramsey joined previously; prior ERI decision remanded on deceit and equitable claims.
- Dregseth worked for Brown 1999–2003 at Capital Harvest and AGSCO; 2005 suit alleged promise of ownership interest as part of compensation.
- Bench trial held June 8–10, 2010 on promissory estoppel, equitable estoppel, and unjust enrichment; witnesses and economists testified.
- District court dismissed remaining claims on January 26, 2011; final judgment entered March 11, 2011; amended July 1, 2011; appeal timely filed.
- Court affirms, holding the district court’s Rule 52(a)(1) findings adequate and affirming dismissal of promissory estoppel, equitable estoppel, and unjust enrichment claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Are the district court’s 52(a)(1) findings sufficient? | Dregseth: findings unclear whether ‘Facts’ are the findings. | Brown: findings sufficient to understand reasoning. | Findings adequate under Rule 52(a)(1). |
| Did the district court err by not rejecting Brown’s testimony entirely due to alleged perjury? | Dregseth: perjured deposition requires rejection of all testimony. | Brown: credibility assessed by court; remaining evidence corroborates. | District court’s partial reliance on Brown admissible; not reversible error. |
| Can promissory estoppel be sustained when the promise is incomplete/ambiguous? | Dregseth: 8% ownership promised; enforceable despite some terms. | Brown: promise lacks clear, definite essential terms; not enforceable. | District court not clearly erroneous; no unambiguous promise; promissory estoppel fails. |
| Can equitable estoppel create an enforceable ownership right when promissory estoppel fails? | Dregseth: equitable estoppel should protect his asserted ownership. | Equitable estoppel is not an affirmative cause of action to create rights. | Equitable estoppel does not create enforceable rights; properly dismissed. |
| Did Dregseth prove unjust enrichment? | Dregseth contends Brown unjustly enriched by not paying value of ownership. | Brown argues no evidence of enrichment or causal link; no unjust enrichment. | Court affirmed dismissal; no proof of enrichment, impoverishment, or causal link. |
Key Cases Cited
- Urlaub v. Urlaub, 325 N.W.2d 234 (N.D. 1982) (trial judge credibility governs witness credibility; clear error standard)
- City of Fargo v. Salsman, 760 N.W.2d 123 (N.D. 2009) (52(a) findings required to support judgment)
- Dalan v. Paracelsus Healthcare Corp., 640 N.W.2d 726 (N.D. 2002) (elements of promissory estoppel)
- Peterson Mechanical, Inc. v. Nereson, 466 N.W.2d 568 (N.D. 1991) (estoppel generally a question of fact)
- Lohse v. Atlantic Richfield Co., 389 N.W.2d 352 (N.D. 1986) (unambiguous terms required for promissory estoppel)
- Cavalier Cnty. Memorial Hosp. Ass’n v. Kartes, 343 N.W.2d 781 (N.D. 1984) (unjust enrichment framework; construct implied contract)
- Zuger v. N.D. Ins. Guar. Ass’n, 494 N.W.2d 135 (N.D. 1992) (unjust enrichment five elements)