Sparks v. Gustafson
Citation: 750 P.2d 338 (Alaska 1988)
Facts
Sparks, a friend of Gustafson, managed Gustafson’s commercial building for several years without compensation — collecting rents, managing tenants, making repairs. Gustafson died and Sparks sought compensation from the estate based on unjust enrichment.
Issue
May a person recover in restitution for services rendered without expectation of payment if the recipient benefited from those services?
Holding
Yes. Sparks was entitled to compensation for the reasonable value of his services under unjust enrichment/quasi-contract theory. The benefits were conferred; the decedent accepted them without protest; and it would be unjust to allow the estate to retain those benefits without compensation.
Rule
Unjust enrichment — services: A party may recover the reasonable value of services rendered without a contract if: (1) services were rendered that benefited the defendant, (2) defendant had an opportunity to accept or reject the services and accepted them, and (3) retention of the benefit without compensation would be unjust. The absence of a formal contract does not bar recovery in restitution.
Significance
- Classic case on quasi-contract recovery for services rendered without a formal agreement
- Distinguished from the “officious intermeddler” doctrine (no recovery for services thrust upon an unwilling recipient)
- Key to unjust enrichment analysis: the question is whether it would be inequitable to allow the defendant to retain the benefit
- Shows that close personal relationships do not necessarily bar restitution claims — the nature of the relationship is a factor in determining whether compensation was expected