John S. & James L. Knight Foundation, Inc. v. Urban Philanthropies, Inc.

In 2001, the Collins Center for Public Policy (Collins Center) submitted a grant application for funding to the John S. & James L. Knight Foundation, Inc. (Knight Foundation) (plaintiff). The Collins Center intended to undertake a community development project for the benefit of Overtown. The Knight Foundation accepted the application and awarded $3 million to the Collins Center, with $1.5 million designated for the purchase of real property by an independent nonprofit corporation referred to as the “land trust.” In 2002, the Collins Center established South Florida Smart Growth Land Trust, Inc. (the land trust) to acquire and develop land for the benefit of the community. The land trust purchased properties using the granted funds. In 2013, the land trust transferred the properties it held to Urban Philanthropies, Inc. (Urban) (defendant), a newly established nonprofit corporation. Urban sold the properties and allegedly misused the proceeds. The Knight Foundation sued Urban and some members of the land trust’s board of directors (defendants) (collectively, Urban), claiming unjust enrichment, among other claims. Urban filed motions for summary judgment. In response, the Knight Foundation argued that it had intended to create a charitable trust. The Knight Foundation’s position was supported by the testimony of its chief executive officer (CEO), other witnesses, and the documents referencing the land trust. The CEO of the Collins Center testified that the parties had not intended to create a trust; rather, the Collins Center had applied for and obtained a grant of funds that it needed to be able to use flexibly to benefit the community. The trial court granted summary judgment for Urban, and the Knight Foundation appealed.