CFLB Partnership, LLC v. Diamond Blue International, Inc.
Lenders loaned $2 million to CFLB Management on promissory notes; Management transferred the funds the next day to affiliated CFLB Partnership as a capital contribution. After obtaining judgment on the notes against Management, the lenders won summary judgment against Partnership for unjust enrichment on the theory that no real economic transaction occurred between the commonly-owned entities. The Third DCA reversed, holding that no direct benefit was conferred on Partnership as a matter of law because plaintiffs dealt only with Management and never sought to pierce the corporate veil.
Key facts
- Lenders loaned $2 million to CFLB Management on promissory notes; Management transferred the funds the next day to affiliated CFLB Partnership as a capital contribution.
- After obtaining judgment against Management on the notes, lenders sought to recover from Partnership on an unjust enrichment theory, arguing that no real economic transaction occurred between the commonly-owned entities.
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Why it matters
This is a strong defense-side authority for dismissing or defeating unjust enrichment claims brought against parent, affiliate, or upstream entities that ultimately received plaintiff's money. The Third DCA squarely… — full analysis with a trial
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