Gazvoda v. Wright

Bruce Gazvoda (plaintiff) and Sabrina Wright (defendant), unmarried, cohabitated for 16 years and had one child, J. For the first four years, Sabrina worked together with Bruce to build Bruce’s company, Electric Services, working long days with him at job sites and managing the company’s administration. Sabrina did not receive any compensation for her work. After J was born, Sabrina primarily took care of raising J and maintaining the house. Bruce and Sabrina had a joint bank account for the business’s income and referred to their assets as “ours.” When J was two years old, Bruce started Bruce’s Investment Properties to manage the rental properties he had built. Sabrina, without pay, managed and maintained the rental properties while continuing to care for J and the household. Over 16 years, the parties’ cumulative assets increased from approximately $2,000 to $1 million. In 2004, Sabrina left Bruce, and Bruce filed a declaratory action for determination of interests in property. Sabrina countered, seeking relief under implied contract and unjust enrichment. At trial, Sabrina’s vocational expert testified that her unpaid work during the relationship should be valued at approximately $472,000. The trial court ordered Bruce to pay Sabrina $250,000 under the theory of unjust enrichment, reasoning that Sabrina worked to build Bruce’s companies in lieu of earning assets in her own name, and that she was entitled to compensation for her efforts from the accumulated property. Bruce appealed, arguing that he compensated Sabrina while they were cohabitating and that unjust enrichment was inappropriate.