594 S.W.3d 120
Ark. Ct. App.2020Background
- Ron Pruitt and Diane Barclay were in a romantic relationship (Aug. 2014–Aug. 2017); Barclay had title to a family home in Dover, Arkansas.
- While together Pruitt paid for and performed substantial renovations to Barclay’s deeded home between 2015–2017.
- Pruitt presented transaction evidence (bank withdrawals and credit-card charges) showing nearly $97,000 spent on the renovations and testified he expected repayment; Barclay testified she considered the work a gift and that she could not have afforded it.
- Pruitt sued for unjust enrichment and constructive trust (he abandoned other claims); after Pruitt rested, Barclay moved to dismiss and the trial court granted the motion, finding Pruitt failed to prove the elements and any quantifiable enrichment.
- On appeal, the Arkansas Court of Appeals reviewed whether Pruitt made a prima facie case sufficient to survive a dismissal at the close of his evidence and reversed and remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument (Pruitt) | Defendant's Argument (Barclay) | Held |
|---|---|---|---|
| Whether Pruitt made a prima facie case of unjust enrichment/constructive trust | Spent ~$97,000 renovating Barclay’s deeded home with expectation of repayment; presented transaction records and photos | The expenditures were a gift; no agreement to repay; insufficient proof of amount of enrichment or change in property value | Reversed — Pruitt’s evidence (amount spent + intent) sufficed to defeat dismissal and present a question for the factfinder |
| Whether plaintiff must prove precise beginning/ending value or overcome speculation to survive dismissal | A coherent theory and reasonable approximation (records of payments + intent) meet the burden to present the claim | Trial court required proof of starting/ending value and exact enrichment amount, making dismissal proper | Reversed — appellate court held claimant need not provide exact valuation at that stage; trial court improperly weighed evidence and credibility |
Key Cases Cited
- Phillips v. Denton, 543 S.W.3d 508 (bench-trial motion-to-dismiss standard; nonmoving party must make a prima facie case to proceed)
- Williamson v. Williamson, 548 S.W.3d 816 (appellate review requires viewing evidence in favor of the nonmoving party and not assessing witness credibility)
- Hartness v. Nuckles, 475 S.W.3d 558 (unjust-enrichment burden met by a coherent theory permitting a reasonable approximation of wrongful gain)