Reyner v. Crawford, 334 S.W.3d 168

Reyner purchased unit 5774A in the McPherson Condominium in 2005; Rainey managed the Association and handled funds with Crawford's involvement.
Crawford owned the adjacent unit 5774; Rainey acted as construction manager and management conduit for Crawford's affairs.
Disputes arose over roof repairs: initial Lawlor Roofing work, subsequent Gomez work, and questions of warranty and payment shares.
Reyner and the Association alleged Crawford and Rainey failed to pay assessments and engaged in mismanagement and conversion of funds.
The trial court entered judgment for Crawford on all counts of Reyner's petition and for Reyner on Crawford's counterclaims; this appeal followed.
The appellate court reviews for substantial evidence, weight of the evidence, and misapplication of law in a bench trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Crawford owed the assessments and special assessments.	Reyner asserts Crawford failed to pay assessments for 2005–2008 and special assessments.	Crawford argues payments were made via Rainey and informal family arrangements; not all funds clearly deposited.	There was substantial evidence supporting Crawford’s payment of assessments; issue denied.
Whether Rainey acted as Crawford's agent regarding the Association finances.	Reyner contends Rainey acted as Crawford’s agent with authority affecting the Association’s finances.	Crawford contends Rainey’s role was limited to construction management; no agency over 5774/Association finances.	Rainey was not Crawford’s agent for the Association; no evidence of actual or apparent authority establishing agency.
Whether Crawford was unjustly enriched by Lawlor Roofing work.	Reyner argues Crawford benefited from Lawlor Roofing and should reimburse half the cost.	Crawford claims Reyner’s later Gomez work voided the warranty and that the law supports unclean hands defenses.	Crawford was unjustly enriched; it would be unjust to retain the benefit without paying value.

Murphy v. Carron, 536 S.W.2d 30 (Mo. banc 1976) (standard of review for bench trials; defer to trial judge on factual credibility)
Essex Contracting, Inc. v. Jefferson County, 277 S.W.3d 647 (Mo. banc 2009) (credibility and trial court’s fact-finding deference in bench trials)
State ex rel. Elson v. Koehr, 856 S.W.2d 57 (Mo. banc 1993) (agency elements: power to alter legal relations, fiduciary duties, principal control)
Ford Motor Company v. Bacon, 63 S.W.3d 641 (Mo. banc 2002) (agency defining characteristics)
Purcell v. Cape Girardeau County Commission, 322 S.W.3d 522 (Mo. banc 2010) (unclean hands principle in equitable relief)
City of St. Joseph v. Lake Contrary Sewer District, 251 S.W.3d 362 (Mo. App. 2008) (unclean hands and equitable relief considerations)
Winslow v. Nolan, 319 S.W.3d 497 (Mo. App. 2010) (unjust enrichment framework and measuring value)
Ken Cucchi Construction, Inc. v. O'Keefe, 973 S.W.2d 520 (Mo. App. 1998) (trial court as finder of credibility; appraisal of witness testimony)
McCormick v. Cupp, 106 S.W.3d 563 (Mo. App. 2003) (credibility and witness testimony considerations in appellate review)