Vautar v. First National Bank of Pennsylvania
133 A.3d 6
| Pa. Super. Ct. | 2016Background
- Frances Sakmar was named as a beneficiary on four First National Bank of Pennsylvania (FNB) CDs originally titled “Jean Sojak in trust for Frances Sakmar/Bertha Vautar.” Confusion arose about who was beneficiary/beneficiaries.
- After Jean Sojak’s death, Frances executed Indemnity Bonds representing she was entitled to the CD proceeds; FNB then released the full proceeds to Frances.
- Bertha Vautar later claimed half the proceeds and sued FNB; FNB sought reimbursement from Frances, who refused and placed the disputed funds in an Oppenheimer account.
- Upon Frances’s death the Oppenheimer account paid the funds to her three children (Appellants). FNB obtained a money judgment against Frances’s estate for $69,188.80 but the estate lacked sufficient assets.
- The trial court entered an amended/supplemental verdict adding Appellants liable on unjust enrichment, reasoning equity was necessary to provide a full remedy; Appellants appealed raising preservation and merits issues.
Issues
| Issue | Plaintiff's Argument (FNB) | Defendant's Argument (Appellants) | Held |
|---|---|---|---|
| Whether Appellants waived issues by not filing post-trial motions to the amended/supplemental verdict | Post-trial motions were required because original verdict did not dispose of all parties/claims; amended verdict was the final order | Remand/amendment did not constitute a new trial under Newman; no new evidence was received so Rule 227.1 did not require new post-trial motions | Appellants did not waive their issues; Newman controls because court only re-evaluated the record and received legal argument, not new evidence |
| Whether unjust enrichment is available when an adequate legal remedy exists against the estate | Equity is appropriate to reach a full recovery when legal remedy against estate is inadequate (estate insufficient to satisfy judgment) | Equitable relief improper because adequate legal remedies were sought and obtained against the estate | Equity was properly invoked; legal remedy against estate was incomplete, so equitable relief was appropriate |
| Whether Appellants can be liable for unjust enrichment absent wrongdoing | FNB argues unjust enrichment does not require beneficiary wrongdoing; retention of funds would be unconscionable given Frances breached indemnity bonds | Appellants contend they committed no malfeasance and merely received funds by virtue of beneficiary designation; wrongdoing required for liability | Held that wrongdoing or bad faith by recipients is not required; unjust enrichment focuses on benefit and resulting injustice, so Appellants liable |
| Whether constructive trust should have been imposed on Appellants’ funds | FNB sought imposition of constructive trust to secure collection | Appellants opposed equitable imposition on funds they received | Court reserved imposition of constructive trust as necessary for collection; judgment against Appellants affirmed on unjust enrichment grounds |
Key Cases Cited
- Newman Dev. Group of Pottstown, LLC v. Genuardi’s Family Mkts., Inc., 52 A.3d 1233 (Pa. 2012) (remand proceedings that merely recalculate or re-evaluate the record without new evidence do not trigger Rule 227.1 post-trial motion requirement)
- Torchia ex rel. Torchia v. Torchia, 499 A.2d 581 (Pa. Super. 1985) (unjust enrichment may be imposed on a recipient of gratuitous benefits even absent recipient wrongdoing)
- First Capital Life Ins. Co. v. Schneider, Inc., 608 A.2d 1082 (Pa. Super. 1992) (equity can provide relief when legal remedy is inadequate or incomplete)
- Martino v. Transport Workers’ Union of Philadelphia, 480 A.2d 242 (Pa. 1984) (a court of equity will provide relief if legal remedies are inadequate to prevent injustice)
- Hill v. Nationwide Ins. Co., 570 A.2d 574 (Pa. Super. 1990) (equitable relief can be appropriate where legal remedy is not full, perfect and complete)