714 F.3d 1234
11th Cir.2013Background
- Merle Wood sued Trinity Yachts for quantum meruit and unjust enrichment after allegedly brokering a deal that led to the sale of two yachts.
- District court granted summary judgment concluding the claims were time-barred under Florida's four-year statute of limitations (Fla. Stat. § 95.11) because accrual occurred before September 8, 2006.
- Merle Wood admitted the first yacht's purchase agreement and a $3.6 million payment occurred in 2003; the second yacht's agreement was in 2006 with an $100,000 payment in August 2006.
- Merle Wood argued accrual occurred later: for the first yacht at delivery in late 2006 and for the second yacht upon each installment payment.
- The court held the four-year period began when Merle Wood conferred a benefit, which, per the complaint, occurred in 2004, triggering accrual well before suit.
- The court rejected Merle Wood’s theory that accrual depended on future benefits or installments, citing Florida law that accrual occurs when services are performed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| When do quantum meruit claims accrue under Fla. law? | Merle Wood contends accrual postponed until future events (delivery/ installments). | Trinity argues accrual occurred when benefits were conferred, here 2004. | Accrual when benefit conferred, here 2004. |
| Is Merle Wood's claim time-barred under Fla. Stat. § 95.11(3)? | Claims may not be time-barred due to contingent future benefits. | Claims accrued in 2004; more than four years before suit, bar applies. | Yes, time-barred; summary judgment affirmed. |
| May plaintiffs amend pleadings to avoid statute-of-limitations issues at summary judgment? | Merle Wood should be able to rely on theories raised in pleadings and amendments. | Courts may not allow amendment by brief arguments; pleadings control. | Pleadings control; no genuine issue created by later arguments. |
Key Cases Cited
- Commerce P’ship 8098 Ltd. P’ship v. Equity Contracting Co., Inc., 695 So.2d 383 (Fla. 4th DCA 1997) (four elements of quantum meruit; accrual when benefit conferred)
- Matthews v. Matthews, 222 So.2d 282 (Fla. 2d DCA 1969) (benefit conferred when services performed; accrual rule)
- Moneyhun v. Vital Indus., Inc., 611 So.2d 1316 (Fla. 1st DCA 1993) (accrual even with pro rata commissions; services performed)
- Barbara G. Banks, P.A. v. Thomas D. Lardin, P.A., 938 So.2d 571 (Fla. 4th DCA 2006) (distinguishes lump-sum vs. contingent fee accrual; not controlling here)