Hunter v. Reece
2011 WY 97
| Wyo. | 2011Background
- Ron and Linda Reece sued Greg and Staci Hunter for money under a contract; district court found no valid contract but awarded unjust enrichment to Reeces; parties stipulated pre-trial that Exhibit A contract was valid and enforceable but disputed its terms.
- Written contract for 708 Broadway provided Hunters provide capital and approve renovations (budget ~$30,000); Reeces to supply labor with Reece managing labor and paying his employees; profits to be split 50/50 after expenses.
- A Fire Contract was later adopted after a fire, paying Mr. Reece $35 per hour for restoring work, with parties agreeing to revert to original terms after completion.
- Project began November 2006, subsequent disputes arose over wages for Mr. Reece’s labor and overall completion quality; Hunters paid others $16,000 to finish after removing Reece.
- In August 2007 the parties agreed the house was restored and original contract resumed; Reeces continued invoicing for employees and expenses but not for Reece’s own labor; trial occurred March 3–4, 2010.
- District court held no contract due to lack of meeting of the minds and awarded all profits to Reeces via unjust enrichment; on appeal, Wyoming Supreme Court reverses, finds contract unambiguous and requiring Reece’s labor be paid as profits, remanding for damages assessment; court declines to address remaining issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the contract existed and if unjust enrichment applied | Reece | Hunters | Contract exists; unjust enrichment not applicable |
| Proper interpretation of contract language | Reece interpreted wages as expenses | Hunters’ interpretation shows profit-based compensation for Reece | Unambiguous terms mean Reece not paid wages; profits split 50/50 |
| Remand for damages due to alleged breaches | Reece breach evidence supports damages | No breach established | Remand for district court to determine damages and any breach effects |
Key Cases Cited
- Union Pacific R.R. Co. v. Caballo Coal Co., 2011 WY 24, 246 P.3d 867 (Wy. 2011) (contract interpretation; focus on plain meaning and four corners when unambiguous)
- Omohundro v. Sullivan, 2009 WY 38, 202 P.3d 1077 (Wy. 2009) (objective contract interpretation; subjective intent irrelevant)
- Wolter v. Equitable Resources Energy Co., 979 P.2d 948 (Wy. 1999) (course of performance evidence limited to ambiguous contracts)
- Sowerwine v. Keith, 997 P.2d 1018 (Wy. 2000) (unjust enrichment not available where express contract exists)
- True Oil Co. v. Sinclair Oil Corp., 771 P.2d 781 (Wy. 1989) (course of performance evid.; limits in absence of ambiguity)