Jeffs v. Stubbs
Utah Supreme Court
970 P.2d 1234 (1999)
The United Effort Plan Trust (UEP) (defendant), affiliated with a church, invited members to build homes on its land and told them they could live there indefinitely, though not sell or mortgage the property. Twenty-one residents (plaintiffs) made valuable improvements to the land on that understanding. In 1984, Rulon Jeffs (defendant) took control of the UEP and declared the residents tenants at will. The residents sued, claiming unjust enrichment; the trial court found the improvements increased the land's value, imposed a constructive trust letting residents stay for life or be compensated, and the UEP appealed, arguing the residents always knew the UEP owned the land and would benefit from any improvements.
Whether, under the doctrine of unjust enrichment, it is unjust for a party receiving a benefit to keep it without compensation when the benefit was not conferred officiously and the conferring party did not intend it as a gift.