Diaz v. Cat Cay Holdings JHR, LLC
The Third DCA reversed a $600,000 final summary judgment on an unjust enrichment claim arising from an oral agreement in which Ruiz paid Diaz's $600,000 yacht club commission in exchange for a $600,000 tree credit. Although both parties pleaded and conceded the existence of a valid enforceable oral contract, the trial court sua sponte concluded the agreement lacked definite essential terms and entered judgment in equity. The appellate court held that because an enforceable express oral contract governed the transaction, unjust enrichment was unavailable as a matter of law, and Diaz was entitled to summary judgment on that count, leaving the breach of contract claim for the jury.
Key facts
- Diaz and Ruiz entered into an oral agreement whereby Ruiz paid Diaz's $600,000 yacht club commission in exchange for a $600,000 tree credit; both parties pleaded and conceded the contract was valid and enforceable.
- The trial court sua sponte determined the oral agreement lacked definite essential terms and entered a $600,000 final summary judgment against Diaz on the unjust enrichment count, despite the parties' admissions that the contract was enforceable.
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Why it matters
The opinion is a clean, citable statement that unjust enrichment cannot support a judgment where the parties themselves have admitted an enforceable express contract esected useful for defendants attacking equitable… — full analysis with a trial
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