Kistler v. Stoddard
Arkansas Court of Appeals
688 S.W.2d 746 (1985)
For over 20 years, Stoddard (plaintiff) had been a tenant farmer planting wheat each fall on Barrett's farm and renewing his lease annually; in fall 1980 he planted his crop as usual, unaware Barrett had died and the farm had been sold to Shannon (defendant), who declined to renew Stoddard's lease, ending it on December 31, 1980. Shannon knew Stoddard had planted the crop, though its value had not factored into the purchase price, and when the wheat matured, Shannon harvested and sold it himself; Stoddard sued for restitution on an unjust-enrichment theory, and the trial court ordered Shannon to reimburse Stoddard's planting costs, which Shannon appealed.
Whether, under the doctrine of unjust enrichment, a person may benefit at the expense of another because of an innocent mistake or unintentional error.