Judicial estoppel; Spohn v Van Dyke Pub Sch; Ownership; Unjust enrichment or quantum meruit

The court concluded that “judicial estoppel bars [plaintiff-]Lauren from claiming ownership of the home she once disavowed, but it does not necessarily bar her from seeking compensation for what she put into it.” Thus, it affirmed the trial court’s dismissal of her constructive trust, breach of contract, quiet title, and injunctive relief claims, reversed the dismissal of her claims for unjust enrichment or quantum meruit, and remanded. The case involved family members entering into an informal agreement regarding property. “Lauren’s claim for constructive trust, breach of contract, quiet title, and injunctive relief are all ultimately derived from her asserted ownership interest in the house.” Because she “unambiguously denied having any such ownership interest in her bankruptcy petition,” the court affirmed the trial court’s grant of summary disposition on those counts. As defendant-Kathryn correctly noted, “Lauren responded ‘No’ when asked in her bankruptcy petition whether she had ‘any legal or equitable interest in any residence, building, land, or similar property.’ Under Spohn, her claims that are predicated on her being the true owner of the house are precluded by judicial estoppel.” Lauren also raised a claim for unjust enrichment or quantum meruit. The court found that her “unjust enrichment claim does not depend on any interest in the house—indeed, the claim can be brought only if she is denied any legal or equitable interest in the house.” Thus, it agreed that she is judicially estopped from recovering certain expenses and affirmed “the trial court’s ruling to that extent.” But it disagreed “that her claim for unjust enrichment or quantum meruit is entirely barred by her bankruptcy statement disclaiming any interest in the house.”