Van Haele v. Kuhl, 2022 MT 69N

Van Haele performed gravel work on defendants' roads in 2018–2019; he claimed the work was in exchange for an easement across Kuhl’s property (no written easement; Kuhl denied any agreement).
After the work, Van Haele removed scrap metal/machinery with defendants’ alleged consent; in 2019 he hauled gravel for Valerie and, at her request, to Jennifer—Valerie paid him by a $275 check with a disputed memo.
A July 2020 fire and subsequent dispute led Kuhl to deny Van Haele the requested easement; on August 3, 2020 Van Haele sent bills for prior gravel work which defendants refused to pay.
Van Haele sued each defendant in justice court, lost all three cases, and appealed to the District Court; he requested joinder of the three causes and the District Court ordered a consolidated bench trial (plaintiff moved to join; defendants did not object).
After a July 14, 2021 bench trial, the District Court found plaintiff’s testimony not credible, found no fraud or unjust enrichment, and entered judgment for defendants; Van Haele appealed but did not provide trial transcripts.
The Supreme Court affirmed: it upheld the District Court’s credibility findings, rejected the unjust-enrichment claim, and found consolidation was not an abuse of discretion; failure to provide transcripts limited appellate review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether District Court erred in denying recovery under unjust enrichment	Van Haele: he conferred benefit (gravel work); defendants received and retained benefit and used fraud/deceit to avoid payment	Defendants: no agreement to pay; testimony showed consent or payment for services; no fraud	Court: Affirmed—elements of unjust enrichment not established; credibility findings favored defendants and appellant failed to supply transcripts to challenge them
Whether consolidation (joinder) of the three cases for trial was an abuse of discretion	Van Haele: consolidation violated his right to a fair trial; he was not informed what rights he waived	Defendants: Van Haele moved to join the cases; they did not object; joinder appropriate under M.R. Civ. P. 20	Court: No abuse of discretion—joinder permissive and plaintiff consented; consolidation proper
Whether appellant’s failure to provide trial transcripts affects review	Van Haele: (argued merits without supplying transcripts)	Defendants/Court: appellant bears burden to provide sufficient record; failure precludes challenging factual findings	Court: Appellant failed to provide a sufficient record; cannot attack District Court’s factual findings; appellate review limited; affirmance appropriate

Associated Mgmt. Servs. v. Ruff, 392 Mont. 139, 424 P.3d 571 (2018) (defines unjust-enrichment elements)
Mont. Digital, LLC v. Trinity Lutheran Church, 401 Mont. 482, 473 P.3d 1009 (2020) (elements required to prevail on unjust-enrichment claim)
In re Marriage of Hodge, 316 Mont. 194, 69 P.3d 1192 (2003) (failure to provide transcript precludes challenging district-court factual findings)
Kurtzenacker v. Davis Surveying, Inc., 365 Mont. 71, 278 P.3d 1002 (2012) (bench-trial credibility determinations are for the trial court)
State v. Shepp, 385 Mont. 425, 384 P.3d 1055 (2016) (when district court tries a justice-court appeal anew, it functions as a trial court and is reviewed accordingly)
Ioerger v. Reiner, 327 Mont. 424, 114 P.3d 1028 (2005) (joinder is discretionary and should be liberally allowed)
Masters Grp. Int’l, Inc. v. Comerica Bank, 404 Mont. 434, 491 P.3d 675 (2021) (standard for reviewing findings after a bench trial)
Heidt v. Argani, 352 Mont. 86, 214 P.3d 1255 (2009) (appellate court’s power to determine whether the record/transcripts are sufficient for review)