IDC Clambakes, Inc. v. Dennis J. Carney, in his capacity as Trustee of the Goat Island Realty Trust, 246 A.3d 927

The GIS Condominium declaration reserved development rights over a waterfront "Reserved Area" (North Development Unit) that expired December 31, 1994. Properties (successor declarant) later built an event facility called the Regatta Club and Clambakes operated it under lease from Properties (circa 1998–2005).
Properties’ attempted extension of development rights prompted litigation (America I/II). This Court held the amendments invalid, Properties’ development rights had expired, and title to the Reserved Area vested in the unit owners.
Clambakes was not a party to America I/II. After those decisions and related proceedings, Clambakes turned over possession of the Reserved Area by consent in Bankruptcy Court; defendants thereafter leased the facility to a new operator.
Clambakes sued the individual unit owners and GISCA claiming unjust enrichment/quantum meruit (and other claims later dismissed), alleging it had conferred goodwill, increased rental value, and other benefits by operating and improving the Regatta Club.
The Superior Court granted summary judgment to defendants, finding that even if Clambakes conferred a benefit, it would not be inequitable for defendants to retain it; the Rhode Island Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Unjust enrichment / quantum meruit: Did Clambakes confer a benefit and would it be inequitable for defendants to retain it?	Clambakes: it built the Regatta Club’s goodwill, increased the value/rental premium of the Reserved Area, and defendants reaped those benefits when they ousted Clambakes and leased to a competitor; valuation and inequity are factual questions for a jury.	Defendants: any benefit resulted from defendants’ lawful recovery of their property after prevailing in the America litigation; Clambakes knowingly operated during the title dispute and cannot claim equitable relief—retention is not unjust.	Affirmed summary judgment for defendants: assuming a benefit, retention was not inequitable because the benefit flowed from defendants’ successful vindication of title; no genuine issue of material fact.
Res judicata / preclusive effect of prior proceedings	Clambakes: bankruptcy and prior proceedings do not bar its quasi-contract claims and actually show defendants benefited.	Defendants: prior final judgments and related litigation preclude relitigation of matters.	Court did not decide res judicata given disposition on inequity; remanded no further relief.

America Condominium Association, Inc. v. IDC, Inc., 844 A.2d 117 (R.I. 2004) (held amendments invalid; development rights contested)
America Condominium Association, Inc. v. IDC, Inc., 870 A.2d 434 (R.I. 2005) (affirmed title vested in unit owners; Properties’ rights expired)
IDC Properties, Inc. v. Goat Island South Condominium Association, Inc., 128 A.3d 383 (R.I. 2015) (prior related litigation concerning the same condominium/common elements)
South County Post & Beam, Inc. v. McMahon, 116 A.3d 204 (R.I. 2015) (articulates elements of unjust enrichment/quantum meruit)
Process Engineers & Constructors, Inc. v. DiGregorio, Inc., 93 A.3d 1047 (R.I. 2014) (quantum meruit defined; quasi-contract principles)
Emond Plumbing & Heating, Inc. v. BankNewport, 105 A.3d 85 (R.I. 2014) (equitable balancing in unjust enrichment context)
Correia v. Bettencourt, 162 A.3d 630 (R.I. 2017) (summary-judgment standard of review)
R & B Electric Co., Inc. v. Amco Construction Co., Inc., 471 A.2d 1351 (R.I. 1984) (courts must balance equities when deciding unjust enrichment)