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Jeffs v. Stubbs

Utah Supreme Court
970 P.2d 1234 (1998)


Facts

The Church of Jesus Christ of Latter-day Saints, through a trust known as the United Effort Plan Trust (UEP) (defendant), owned a plot of land. The UEP invited members of the church to build homes and live on the land. The UEP told its members that they could live on the land for as long as they wished, but could not mortgage or sell the land. In 1984, Rulon Jeffs (defendant) took control of the UEP and informed the residents that they were tenants at will. Twenty-one residents (plaintiffs) who had made improvements on the land sued Jeffs and the UEP, arguing that the UEP had been unjustly enriched by the improvements to the land. The trial court found that the plaintiffs’ improvements to the land increased the value of the land. The trial court imposed a constructive trust in favor of the plaintiffs, and found that they were entitled to live on the land for their lifetimes, or to compensation for the improvements they made. UEP appealed, arguing that because the plaintiffs knew that the UEP owned the land, they knew that the UEP would be entitled to reap the benefit of the improvements.

Rule of Law

Issue

Holding and Reasoning (Zimmerman, J.)

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