Graffagnino v. Lifestyles, Inc.

Lifestyles, Inc. (defendant) entered into a lease with Leeand, Inc., that allowed Lifestyles to install a dome-like structure it owned on Leeand’s land. Under the lease agreement, Lifestyles retained ownership of the structure. Lifestyles never recorded the lease or its ownership of the structure. Leeand eventually sold the land on which the structure was installed to A. J. Graffagnino and Donald Perez (plaintiffs). Leeand informed Graffagnino and Perez that the structure belonged to Lifestyles prior to the sale of the land, and Lifestyles was aware that the sale was pending. Lifestyles did nothing to protect its ownership of the structure, neither removing it, recording its lease, or negotiating an agreement for continuation of the lease with the new owners. The deed of sale for the land specified that the sale included all building on the land and did not include any exclusion for Lifestyle’s structure. After they purchased the land, Graffagnino and Perez filed a petition to enjoin Lifestyles from removing the structure from the land. Lifestyles claimed it still owned the structure. In the interim, the building was destroyed, and Lifestyles demanded $15,000 in damages. Lifestyles then added Leeand to the suit, claiming that Leeand was liable if it failed to inform Graffagnino and Perez of Lifestyles’s ownership of the structure. The trial court held that ownership of the structure had transferred with the land. The trial court ordered Leeand to pay Lifestyles $8,000 for the loss of the building, however, on the theory that Leeand would be unjustly enriched if it was allowed to profit from the sale of a structure it did not own.