Partnership formation; MCL 449.6; MCL 449.7; Byker v Mannes; Unjust enrichment; Morris Pumps v Centerline Piping, Inc; Equitable property award

The court held that the trial court did not err by finding no partnership between the parties, rejecting plaintiff’s unjust enrichment claims, and limiting the equitable campground award to the property defendant promised at trial. The parties were formerly in a long-term relationship, owned properties, and operated small businesses. Plaintiff later deeded all properties to defendant during a period of serious medical issues. After the relationship ended, defendant returned several parcels and paid off associated mortgages. Plaintiff sued, alleging a business partnership and unjust enrichment. The trial court rejected those claims after a bench trial. On appeal, the court held that the trial judge’s credibility findings were paramount, noting “there was no testimony presented about profit-sharing” and no partnership records. It further found no inequitable retention of benefits because defendant “paid all [plaintiff’s] bills and provided his housing free of charge for the past 12 years.” The court also found no error regarding personal property plaintiff failed to retrieve and no basis for a life estate in a property where plaintiff had been living. Finally, the court upheld the award of two campground parcels because it reflected defendant’s “promise during trial,” which the court could enforce in equity. Affirmed.