The district court further noted that the commissions were earned when respondents obtained fully executed and enforceable purchase agreements on each of the involved properties. The district court also reasoned that to allow appellant to retain the commissions would result in unjust enrichment, and that under Schumacher v. Schumacher, 627 N.W.2d 725, 729 (Minn.App. 2001), unjust enrichment need not be pleaded with specificity. Appellant contends that respondents' claims are barred by the two-year statute of limitations in Minn. Stat. § 541.07(5).

. A22-1706, 2023 WL 5341094, at *2 (Minn.App. Aug. 21, 2023) (citing Schumacher v. Schumacher, 627 N.W.2d 725, 729 (Minn.App. 2001) and Park-Lake Car Wash, Inc. v. Springer, 394 N.W.2d 505, 514 (Minn.App. 1986)). The court of appeals concluded that "[t]he record adequately evidences Meadowcroft's inducing Hepfl to expend funds to improve the property" and "supports the district court's discretionary decision to deny Meadowcroft an inequitable windfall" because (1) "Hepfl testified that he improved the Norcross property after Meadowcroft told him that he could use the property as his own," (2) "the district court implicitly credited Hepfl's testimony," and (3) Meadowcroft did not dispute that she made that representation to Hepfl.

Aug. 16, 2011). "[T]o prevail on a claim of unjust enrichment, a claimant must establish an implied-in-law or quasi-contract in which the defendant received a benefit of value that unjustly enriched the defendant in a manner that is illegal or unlawful," Caldas, 820 N.W.2d at 838, or "morally wrong," Schumacher v. Schumacher, 627 N.W.2d 725, 729-30 (Minn. App. 2001). In this case, the district court found that Lloyd made "only one promise or inducement: the promise to marry" and, despite Anderson's argument to the contrary, that "the promise to marry [wa]s the basis for [Anderson]'s unjust enrichment claim."

The Receiver contends that three cases, Wells Electric, Inc. v. Schaper, No. A06-420, 2006 WL 2807179 (Minn.Ct.App. Oct. 3, 2006), Honeywell/Alliant Techsystems Federal Credit Union v. Buckhalton, No. C2-99-1194, 2000 WL 53875 (Minn.Ct. App. Jan. 25, 2000), and Kranz v. Koenig, 484 F.Supp.2d 997 (D.Minn. 2007), support her argument that she need not plead that CitiMortgage or ABN AMRO committed some wrong in order to recover under an unjust enrichment theory. CitiMortgage cites two cases, Schumacher v. Schumacher, 627 N.W.2d 725, 729 (Minn.Ct.App. 2001), and Southtown Plumbing, Inc. v. Har-Ned Lumber Co., Inc., 493 N.W.2d 137, 140 (Minn.Ct.App. 1992), for the opposite proposition. The Magistrate Judge found the reasoning in the Receiver's cited case law persuasive and concluded that "the Receiver was not required to allege that CitiMortgage knowingly received stolen investor money."

To establish a cause of action for unjust enrichment, it must be shown that a party has "knowingly received something of value, not being entitled to the benefit, and under circumstances that would make it unjust to permit its retention."Southtown Plumbing, Inc. v. Har-Ned Lumber Co., Inc., 493 N.W.2d 137, 140 (Minn.Ct.App. 1992); see also Schumacher v. Schumacher, 627 N.W.2d 725, 729 (Minn.Ct.App. 2001). "The most significant element of the doctrine is whether the enrichment of the defendant is unjust; the doctrine does not apply simply because the defendant may have benefited as a result of the actions of the plaintiff."

See generally, Olson v. Synergistic Technologies Bus. Sys., Inc., 628 N.W.2d 142 (Minn. 2001) (discussing the history of promissory estoppel and its applications in Minnesota Courts); Schumacher v. Schumacher, 627 N.W.2d 725, 728 (Minn.Ct.App. 2001). In this case, however, the parties bargained for a written contract that contained a condition precedent.

"[T]o establish a claim for unjust enrichment, the claimant must show that another party knowingly received something of value to which [they were] not entitled, and that the circumstances are such that it would be unjust for that person to retain the benefit." Schumacher v. Schumacher, 627 N.W.2d 725, 729 (Minn.App. 2001). In this context, "unjust" means that retaining the benefit is illegal, unlawful, or morally wrong.

However, appellant argues that litigants are permitted to plead alternative theories of relief and, therefore, it was improper to dismiss the unjust enrichment claim before discovery. Appellant relies on Schumacher v. Schumacher, 627 N.W.2d 725, 729 (Minn. App. 2001) for the proposition that it is improper to dismiss an unjust enrichment claim on a motion for judgment on the pleadings. In Schumacher, this court overturned the district court's finding that the plaintiff did not plead unjust enrichment with enough specificity.

Likewise, to obtain relief under the equitable theory of unjust enrichment, a claimant must not only demonstrate that "another party knowingly received something of value to which he was not entitled," but also that the "circumstances are such that it would be unjust for that person to retain the benefit." Schumacher v. Schumacher, 627 N.W.2d 725, 729 (Minn. App. 2001). A district court must find by clear and convincing evidence that a constructive trust is justified to prevent unjust enrichment.

A party succeeds on an unjust-enrichment claim when he establishes that (1) a party knowingly received something of value, (2) the recipient was not entitled to the thing of value, and (3) it would be unjust to allow the recipient to retain the benefit. Schumacher v. Schumacher, 627 N.W.2d 725, 729 (Minn. App. 2001). Generally, an unjust-enrichment claim does not lie simply because a party benefits from the efforts of another; instead, "it must be shown that a party was unjustly enriched in the sense that the term unjustly could mean illegally or unlawfully."