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Paffhausen v. Balano

Maine Supreme Judicial Court
708 A.2d 269 (1998)


Facts

In 1990, David Paffhausen (plaintiff) and Elizabeth Balano reached an agreement under which Paffhausen would renovate a building that Balano owned. Paffhausen would then use it for an art studio for as long as he needed it. Pursuant to the agreement, Paffhausen would pay Balano $60 per month to use the building after his art studio was active. Paffhausen renovated the building, with Balano signing various town permitting documents and writing a letter stating that Paffhausen could use the building as long as he needed. In 1995, Balano died. Balano’s estate (defendant) offered Paffhausen the use of the building for free for one year, after which he would have to pay $60 per month in rent. Paffhausen rejected the offer because it would have rendered him a tenant at will. Paffhausen filed a claim against Balano’s estate based on his agreement with Balano. The estate rejected the claim. Paffhausen brought suit in Knox County Probate Court. The probate court denied Paffhausen recovery on the theory of quantum meruit, but granted Paffhausen $12,300 based on the theory of unjust enrichment for the improvements Paffhausen had made to the building. Paffhausen appealed.

Rule of Law

Issue

Holding and Reasoning (Clifford, J.)

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