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Specialty Restaurants Corp. v. D.K. Patterson Construction Co.

Citations: 582 So. 2d 1220; 1991 Fla. App. LEXIS 5711; 1991 WL 110464Docket: No. 90-02378

Court: District Court of Appeal of Florida; June 21, 1991; Florida; State Appellate Court

Narrative Opinion Summary

D.K. Patterson Construction Company, Inc. sought damages for breach of contract against Specialty Restaurants Corporation. The trial court ruled in favor of Patterson based on a claim of unjust enrichment, which was not included in the pleadings or supported by evidence. Specialty appealed this judgment. The appellate court reversed the decision, citing precedents that establish a party cannot recover for unjust enrichment unless it is pleaded or tried with the other party's consent. No evidence was provided to indicate that the issue of unjust enrichment was tried with Specialty's consent. Consequently, the appellate court remanded the case to the trial court with instructions to enter a final judgment in favor of Specialty. Judges Threadgill and Parker concurred with the decision.

Legal Issues Addressed

Appellate Court Authority in Remand

Application: The appellate court instructed the trial court to enter a final judgment in favor of Specialty Restaurants Corporation upon remand.

Reasoning: Consequently, the appellate court remanded the case to the trial court with instructions to enter a final judgment in favor of Specialty.

Pleading and Trial Consent

Application: The case was remanded due to the absence of any evidence indicating that the issue of unjust enrichment was tried with the consent of Specialty Restaurants Corporation.

Reasoning: No evidence was provided to indicate that the issue of unjust enrichment was tried with Specialty's consent.

Unjust Enrichment Recovery Requirements

Application: The appellate court reversed the trial court's decision because unjust enrichment was neither pleaded nor tried with the consent of Specialty Restaurants Corporation.

Reasoning: The appellate court reversed the decision, citing precedents that establish a party cannot recover for unjust enrichment unless it is pleaded or tried with the other party's consent.