Potter's Shopping Center, Inc. v. Szekely, 461 S.W.3d 68

2007 Szekelys entered a cost-plus contract with Delk Construction to build a house; Delk financed via construction loan with draw pro rata to work completed.
Delk procured materials from Potter’s Shopping Center; Potter’s maintained an open account and sent monthly statements to Delk.
Delk’s construction ran over budget; Delk encountered financial troubles and stopped work in September 2008; Szekelys paid out-of-pocket to keep going.
Potter’s later claimed Delk owed $33,647.56; Delk later filed for bankruptcy in 2010, extinguishing that debt.
Potter’s filed a 2010 unjust enrichment complaint against the Szekelys seeking $33,647.56; Potter’s moved for summary judgment in May 2012; court granted partial summary judgment on liability, reserving damages.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court complied with Rule 56.04 by stating grounds for the summary judgment.	Potter’s contends grounds were implied by undisputed facts.	Szekelys argue the record shows disputed facts and no stated grounds in the order.	No; the order failed to state the legal grounds, requiring vacatur and remand.
Whether the record supports entry of summary judgment on unjust enrichment.	Potter’s asserts undisputed facts show Szekelys benefited without payment and remedies exhausted.	Szekelys contend Potter’s failed to exhaust remedies against Delk or show futility.	Unable to determine based on record; insufficient to uphold without stated grounds; remand warranted.

Smith v. UHS of Lakeside, Inc., 439 S.W.3d 303 (Tenn.2014) (mandatory grounds requirement under Rule 56.04; explains legislative purpose and need for explanation)
Freeman Indus., LLC v. Eastman Chem. Co., 172 S.W.3d 512 (Tenn.2005) (elements of unjust enrichment and exhaustion of remedies)