Abrams v. Unity Mutual Life Insurance Co.

Abrams (plaintiff) provided consulting services to Unity Mutual Life Insurance Company (defendant) under an oral agreement that included commissions on certain sales. After Unity terminated the relationship, Abrams sued for unjust enrichment, seeking payment of the promised commissions.

Whether an unjust-enrichment claim may be barred by the statute of frauds where it is based on the same promise and seeks the same relief as a contract claim otherwise barred by the statute.