City of Monroeville v. Diversified Development Group
Docket: Civ. 6923
Court: Court of Civil Appeals of Alabama; July 13, 1989; Alabama; State Appellate Court
An appeal has been filed by the City of Monroeville regarding a judgment of $7,850 awarded to motel developers for expenses incurred in paving a public road adjacent to their property. The developers' complaint included counts for implied contract and declaratory judgment. The trial court granted summary judgment in favor of the developers, allowing them to receive reasonable reimbursement for paving costs. Additionally, partial summary judgment found the City liable for payment of reasonable expenses that benefited both the City and the public. The appeal raises two main issues: 1) whether a municipal corporation can reimburse private developers for expenses incurred in paving a public road, and 2) whether the trial court erred in determining the City’s liability under an implied contract. Although the developers did not initially request reimbursement until after the work was completed, the City had previously expressed willingness to pay half of the expenses, contingent on legal authority. Minutes from a council meeting indicated that the council acknowledged a prior agreement to pave the street and planned to address the reimbursement issue legally. However, following an opinion from the Attorney General stating that there was no legal authority for such reimbursement after the fact, the City refused the developers' request. The court referenced the case of Bethune v. City of Mountain Brook, which established that a municipal corporation could be held liable under an implied contract if it accepted benefits without providing just compensation. This principle is supported by prior case law emphasizing the obligation of a municipality to act justly when it benefits from another's efforts. A municipality is obligated to refund money or restore property obtained by mistake or without legal authority, based on a general duty to administer justice. This obligation is not reliant on a contract but is rooted in the principles of equity and preventing unjust enrichment. The case of Hendrix, Mohr, Yardley, Inc. v. City of Daphne reinforces that a municipality can be held liable on an implied contract, either from its actions or to avoid benefiting without compensation. The court confirmed that paving a public street falls within the municipality's corporate powers, and there were no genuine factual disputes affecting the trial court's summary judgment favoring the appellees. The appellant's claim that the trial court improperly awarded $7,850 based on the street's width was unsupported; the trial court's decision was backed by evidence regarding reasonable costs for the work done. The measure of damages was determined to be the reasonable value of the benefits retained by the City. The trial court's judgment was affirmed, supported by credible evidence and consistent with legal standards, with concurrence from all judges involved.