Packard, D.M.D., M.S. v. OCA, Inc.
United States Court of Appeals for the Fifth Circuit
624 F.3d 726 (2010)
Orthodontist Packard (plaintiff) entered a practice-management agreement with OCA (defendant), which the parties agreed was illegal (constituting unlicensed practice of dentistry by OCA); after Packard terminated the deal five years in and sued for a declaration voiding it, OCA counterclaimed for unjust enrichment seeking back several million dollars in net benefits it had paid Packard, and the trial court barred OCA's equitable counterclaims.
Whether a party to an illegal contract may recover benefits conferred under it where the party cannot establish a right to recover independent of the illegal contract, the parties are equally culpable (in pari delicto), or public policy does not favor relief.