77 So. 3d 139
Ala.2011Background
- Matador supplied materials to Stratford for converting HoPo’s leased property into a production facility; Stratford defaulted on rent and Matador filed a materialman’s lien securing judgment against Stratford goods and the lease term; HoPo, as lessor, contested the lien and the unjust-enrichment claim; lease prohibited liens on HoPo’s reversion and required Stratford to comply with plan/insurance/licensing requirements; HoPo’s property manager and Stratford’s lessee relationship were central to notice and knowledge issues; trial court held Matador’s lien could attach to the goods and the unexpired lease term, but denied unjust enrichment.”,
- Matador sought to collect $47,915.24 for materials and asserted lien on HoPo’s property; HoPo argued statutory lien rights did not attach due to Stratford’s lease-terms violations; the trial court denied the unjust-enrichment claim and upheld the lien only to the extent consistent with the lease restrictions; on appeal, the Alabama Supreme Court consolidated the Matador v. HoPo appeals.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether unjust enrichment supports Matador against HoPo | Matador | HoPo | Unjust enrichment denied; no misrepresentation or reliance shown by HoPo. |
| Whether Matador’s materialman’s lien is enforceable against HoPo’s property | Matador | HoPo | Lien unenforceable against HoPo’s property due to Stratford’s violation of lease terms. |
| Whether the lien attaches to the unexpired lease term as permitted | Matador | HoPo | Lien cannot attach given lease-terms violations and lack of authorized lien procedures. |
Key Cases Cited
- Portofino Seaport Vill., LLC v. Welch, 4 So. 3d 1095 (Ala. 2008) (unjust-enrichment standards applicable in aid of restitution)
- Welch v. Montgomery Eye Physicians, P.C., 891 So. 2d 837 (Ala. 2004) (unjust enrichment elements and proofs)
- Jordan v. Mitchell, 705 So. 2d 453 (Ala. Civ. App. 1997) (unjust-enrichment retention of benefit requires donor mistake or recipient misconduct)
- American Family Care, Inc. v. Fox, 642 So. 2d 486 (Ala. Civ. App. 1994) (elements of unjust enrichment: knowledge, retention, and expectation of compensation)
- Reed v. Board of Trs. for Alabama State Univ., 778 So. 2d 791 (Ala. 2000) (ore tenus review limitations and standard of review)