Having a favorite case in Contracts class was probably a sign that going to law school was a good choice. That being said, my favorite Contracts case was Mitchell v. Moore, for the interesting legal theory, fascinating final opinion, and fun fact pattern. I have attached my old law school case brief below, but you can read the whole thing here on FindLaw.com. First, the facts. Mr. Thomas Mitchell of South Carolina and Dr. William Moore of Pennsylvania were in a "committed romantic relationship" when Moore invited Mitchell to spend his “off season” at Moore's Chester County farm. Eventually Mitchell moved in for good and started helping on the farm. "[T]he parties conducted themselves around the home like parties in a loving relationship; they shared household chores, cooked dinners for each other, bestowed gifts upon one another, attended events together, and shared holidays and special occasions with Moore's family." Even if you don't read the whole case, paragraph 16 is my favorite since it is the only time I have seen a contracts opinion rest on the language from a love letter: "The time I have given you breaking my back with the house and grounds were just that, a gift to our relationship." Eventually though, as with all things, the relationship ended and Mitchell moved off of Moore's farm. While breakups are hard at the best of times, unfortunately for Thomas Mitchell he was living in 1990s Pennsylvania so his relationship with Moore had no legal recognition. Gay marriage wasn't legal in PA until the Middle District forced PA to legalize gay marriage in 2014. The good news for Mitchell was that his lawyer was a trixie one. Mitchell's lawyer didn't frame the case as a family case, he farmed it as a contracts case under the doctrine of unjust enrichment. The TL;DR of unjust enrichment is it is an equitable doctrine that lets a party collect for a benefit unjustly given to another. It is rarely used, but it gives courts a method to reimburse one party in situations that seem unfair. For example, if Themis prof George S. Geis's Mother-in-Law convinces a Winery to give her a expensive case of wine for a charity auction to raise money for the Orphans, Puppies, and Wounded Veterans Society, but she actually just drinks all the wine that night alone at Prof. Geis's house, it doesn't sound fair to the Winery to be out the cost of the wine for Geis's Mother-in-Law's benefit. Likewise, Mitchell argued that it was unfair that Moore got the many years of hard work from Mitchell in exchange for... love? In an interesting move for a 1990s court in the PA 'Burbs, the Court found that love was enough and found in favor of Moore. "To find restitution (compensation) proper for services performed in such a relationship, we would curtail the freedom associated in forming new personal bonds based upon the important facet of mutual dependence." Sadly for my own legal curiosity, there was never a Mitchell line of cases. Mitchell v. Moore is now only really known because there aren't that many clear unjust enrichment cases to put in the casebook. Still, I think it is fun. Mitchell v. Moore |
AuthorJared Paul Miller is a New Jersey attorney at law and a published author. His work focuses on data privacy, cybersecurity, transactional, and intellectual property law. ArchivesCategories
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