Schreiber Bros. Hog Co. v. Schreiber, 980 N.W.2d 890

Jerald and Steven formed Schreiber Brothers Hog Company, LLC in 2011; each owned 50% and later Steven sought judicial dissolution.
A receiver was appointed to wind up the company; two hog-production buildings were company-owned but located on land owned solely by Jerald.
The receiver received only one offer—to Jerald—for $18,000 (assessed value); an appraiser valued the buildings at roughly $450,000 and the receiver had difficulty finding buyers because there was no easement for access.
The parties agreed the receiver would accept Jerald’s $18,000 offer but preserved the company’s claim for unjust enrichment against Jerald for potential additional recovery.
The district court found Jerald unjustly enriched and awarded the company approximately $400,184 more; it also denied Jerald’s motion for further directions to the receiver.
The Nebraska Supreme Court dismissed the appeal as to the motion denial for lack of jurisdiction, reversed the unjust-enrichment judgment, and remanded with directions to enter judgment for Jerald.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the company could recover for unjust enrichment when Jerald bought the buildings for $18,000	Company: sale at $18,000 would unjustly enrich Jerald because buildings had much greater value and only he could use them without an easement	Jerald: mere economic disparity or a better deal does not establish unjust enrichment; sale was legally valid and agreed	Reversed: unjust enrichment not proven—no inadequate legal ground, no expectation Jerald would pay, and parties had agreed to the sale price
Whether the district court’s valuation/damage calculation was correct	Company: damages equal fair value (~$418k+) minus $18k	Jerald: valuation and condition evidence undermined award	Not reached—the Supreme Court reversed on liability, so damages analysis unnecessary
Whether the order denying Jerald’s motion for further directions to the receiver was appealable	Jerald: order denying directions is appealable under receiver/final-order statutes	Company: order was not a final, appealable determination	Dismissed in part: Supreme Court lacked jurisdiction—denial did not end a discrete phase or affect a substantial right

City of Scottsbluff v. Waste Connections of Neb., 282 Neb. 848, 809 N.W.2d 725 (Neb. 2011) (unjust-enrichment must allege restitution principles courts will recognize)
Bloedorn Lumber Co. v. Nielson, 300 Neb. 722, 915 N.W.2d 786 (Neb. 2018) (definition and contours of unjust enrichment in Nebraska)
Trickett v. Spann, 613 S.W.3d 773 (Ark. Ct. App. 2020) (recovery for improvements where defendant understood claimant expected payment)
Sutton v. Killham, 285 Neb. 1, 825 N.W.2d 188 (Neb. 2013) (orders in receivership can affect substantial rights and be appealable)
In re Estate of McKillip, 284 Neb. 367, 820 N.W.2d 868 (Neb. 2012) (discrete-phase analysis in probate/receptive proceedings for appealability)
Kalkowski v. Nebraska Nat. Trails Museum Found., 290 Neb. 798, 862 N.W.2d 294 (Neb. 2015) (recipient of benefit not unjustly enriched merely by receipt without more)
Washa v. Miller, 249 Neb. 941, 546 N.W.2d 813 (Neb. 1996) (unjust-enrichment doctrine requires absence of agreement)