Britt v. Britt

Betsy Britt (plaintiff) was married to Robert Dixon Britt (Bobby) (plaintiff). Betsy and Bobby worked as Amway distributors for Bobby’s brother, Billy Britt (defendant). In 1977 Billy purchased a horse farm, and Bobby and Betsy agreed to occupy and run the farm. Billy promised to convey the farm to Bobby and Betsy if they achieved diamond-level Amway sales and repaid Billy for his investment in the farm. Further, Bobby and Betsy would be required to repair and maintain the farm, operate the stable business, and pay the two mortgages on the farm from the farm income. Any surplus income would be Bobby and Betsy’s compensation. After 18 months, Betsy asked Billy to put their agreement in writing. Billy refused. Betsy said that because she was putting so much money into the farm, she needed protection. Billy offered to make Betsy an employee of the farm, but Betsy refused because she knew there was no money left from the farm’s income to pay any employees. Billy then said he was forming a corporation and asked Betsy what she thought of receiving stock each time she made a mortgage payment, and Betsy agreed. Although Betsy continued to make mortgage payments, Billy did not issue Betsy any stock. In 1983 Bobby and Betsy separated, and Billy demanded that Betsy leave the farm. Betsy did and filed suit seeking a parol trust on the farm and asserting claims for unjust enrichment and fraud. During trial, evidence was produced that Bobby and Betsy made $98,126 in mortgage payments on the farm and paid $40,469 in repairs. An expert witness testified that Betsy’s labor and services performed for the farm were valued between $224,415 and $338,833. Finally, the fair market value of the farm increased from $175,000 to $337,500. The jury found against Bobby and Betsy on the parol trust, but it awarded Betsy $363,616 in unjust-enrichment damages as well as $1 in compensatory damages and $400,000 in punitive damages for fraud. Billy appealed, and the appellate court reversed, holding there was insufficient evidence of unjust enrichment or fraud. Betsy appealed.