Linda Carlson v. Larry Brabham, 199 So. 3d 735

Carlson and Brabham cohabited beginning in 2004; Carlson remained married to another man during the relationship.
Brabham operated Longhorn Logging (later dissolved) and used its funds to pay for the Amazing Grace Lane property and the East Fork Road house; Carlson did bookkeeping and performed minor labor.
Longhorn Logging’s status and ownership were disputed, with Carlson claiming a partnership and a share in profits; Brabham kept titles in his name.
Carlson sought equitable division of Longhorn Logging assets and the East Fork Road house; Brabham moved for a directed verdict.
Chancellor adopted Brabham’s findings, ruled no partnership existed, and granted directed verdict; Carlson appealed on multiple theories including partnership, joint venture, unjust enrichment, and sweat equity.
This appeal addresses statute-of-limitations and merits on partnership, joint venture, unjust enrichment/constructive trust, and sweat equity claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Carlson filed within the three-year limit.	Carlson contends accrual delayed until 2009 or ongoing ownership interests.	Brabham argues accrual occurred at the 2007 deed closing, barred by the three-year period.	Carlson’s claims barred; accrual date fixed at 2007.
Whether Brabham and Carlson formed a partnership in Longhorn Logging.	Carlson asserts partnership via intent, control, and shared profits.	Brabham contends no partnership due to lack of intent and proper control.	No partnership; intent and control not proven; ruling affirmed.
Whether Brabham and Carlson formed a joint venture.	Carlson claims joint venture exists based on combined property and efforts.	Brabham argues no joint venture due to lack of mutual intent and profit-sharing structure.	No joint venture; claim barred by limitations and insufficient intent.
Whether Brabham was unjustly enriched and a constructive trust should be imposed on the East Fork Road house.	Carlson seeks a constructive trust based on unjust enrichment from Brabham’s use of proceeds.	Brabham argues no unjust enrichment and no basis for constructive trust.	No constructive trust; sufficient evidence not shown.
Whether Carlson was entitled to sweat equity.	Carlson argues labor constitutes sweat equity deserving compensation.	Brabham contends sweat equity is not a recognized cause of action here.	Sweat equity not recognized; claim meritless and time-barred.

Summers v. A-1 Cash Inc., 911 So. 2d 975 (Miss. Ct. App. 2005) (intent and profit-sharing factors govern partnership analysis)
Smith v. Redd, 593 So. 2d 989 (Miss. 1991) (profit sharing as key indicator of partnership)
Crowe v. Smith, 603 So. 2d 301 (Miss. 1992) (intent evidenced by writings and conduct; partner-like relations)
Hults v. Tillman, 480 So. 2d 1134 (Miss. 1985) (joint venture requires actual intent and mutual control)
Pittman v. Weber Energy Corp., 790 So. 2d 823 (Miss. 2001) (joint venture defined; contract-law framework)
Jones v. Graphia, 95 So. 3d 751 (Miss. Ct. App. 2012) (sweat equity not recognized as basis for equitable division)
Planters Bank & Tr. Co. v. Sklar, 555 So. 2d 1024 (Miss. 1990) (constructive trust elements require clear proof)
Boxwell v. Champagne, 229 Miss. 355, 91 So. 2d 256 (Miss. 1956) (loaned funds within venture treated as loan, not joint venture)
Sojourner v. Sojourner, 247 Miss. 342, 153 So. 2d 803 (Miss. 1963) (confidential relationships in domestic contexts)