Wilberg v. Hyatt
285 P.3d 1249
Utah Ct. App.2012Background
- Dispute over an alleged oral contract for Hyatt to convey Rock Canyon Ranch to the Wilbergs upon Hyatt's death, with the Wilbergs claiming they would work for Hyatt until death and then care for Hyatt's son.
- Wilbergs contend they performed decades of work and invested labor and funds for an irrigation system on Rock Canyon Ranch, using federal funding.
- Hyatt later sold Rock Canyon Ranch to Magnuson; the Wilbergs filed a lien and asserted breach of contract and unjust enrichment claims.
- District court granted Hyatt partial summary judgment on breach of contract, effectively disposing of related claims against Magnuson.
- Bench trial on unjust enrichment concluded with rejection of that claim against Hyatt, leading to appellate review.
- Court affirms in part (breach of contract) and reverses/remands in part (unjust enrichment related to irrigation systems).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Enforceability of oral contract under part performance | Wilbergs assert clear terms and exclusive reliance on contract; acts show part performance | Contract lacks clear, definite terms; acts not exclusively referable to contract | Part performance not proven; no enforceable oral contract under part performance |
| Adequacy of moving papers under Rule 7 | Hyatt/Magnuson failed to provide properly stated undisputed facts | Noncompliance was harmless technical violation | No abuse of discretion; summary judgment on merits stands; noncompliance not reversible |
| Unjust enrichment scope for irrigation systems | Labor and materials for irrigation on Rock Canyon and Clawson Ranch confer benefit to Hyatt | Benefit allocation between properties and reliance on oral contract unclear | Reversed and remanded for reconsideration of unjust enrichment regarding irrigation systems (allocation and valuation to Hyatt) |
Key Cases Cited
- Martin v. Scholl, 678 P.2d 274 (Utah 1983) (part performance requires clear terms and exclusive reliance on contract when proving exception to statute of frauds)
- Randall v. Tracy Collins Trust Co., 305 P.2d 480 (Utah 1956) (flexibility of part performance when contract is not clearly established)
- Van Natta v. Heywood, 195 P.2d 192 (Utah 1920) (necessity of exclusive referability of acts to contract in part performance)
- Bradshaw v. McBride, 649 P.2d 74 (Utah 1982) (acts of performance must be exclusive to contract to enforce oral agreement)
- In re Roth's Estate, 269 P.2d 278 (Utah 1954) (early authority on reliance and estoppel in contract formation)
- Stern v. Metropolitan Water Dist. of Salt Lake & Sandy, 274 P.3d 935 (Utah 2012) (summary-judgment standard in part performance context)
- Jackson v. Dabney, 645 P.2d 613 (Utah 1982) (truth of material facts for summary judgment)
- Heglar Ranch, Inc. v. Stillman, 619 P.2d 1390 (Utah 1980) (summary judgment evaluation when facts are contested)