Young v. Young
Washington Supreme Court
191 P.3d 1258 (2008)
- Written by Salina Kennedy, JD
Facts
Judith Young (defendant) owned an otter sanctuary and wanted to relocate it. Judith’s nephew, Jim Young (plaintiff) and his wife, Shannon Young (plaintiff) located a suitable property in need of improvement, and the three agreed that Jim and Shannon would make the necessary improvements. Judith bought the property and added Jim’s name to the title so that he could obtain the necessary permits. Jim believed that Judith would pay him for his work on the property, and Judith knew that Jim expected payment. Jim and Shannon made extensive repairs and improvements, incurring costs for debris removal, permitting, taxes, and other expenses. Expert testimony established that if a contractor had done the work, it would have cost Judith $760,382. The improvements increased the property’s value by between $750,000 and $1,050,000. Judith decided not to relocate her otter sanctuary and did not pay for the improvements. Judith sued Jim and Shannon to quiet title in the property, and Jim and Shannon counterclaimed for unjust enrichment. The trial court awarded Jim and Shannon $501,866, which represented the value of their work reduced by the costs they had incurred in making the improvements. The appellate court reversed, asserting that full market value was the proper measure of recovery, and Judith appealed.
Rule of Law
Issue
Holding and Reasoning (Sanders, J.)
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