Robinson v. Robinson
Appellate Court of the Second District of Illinois
100 Ill. App. 3d 437 (1981)
Ann Robinson (plaintiff) sued her husband Wylie for divorce and sued his parents Earl and Alice Robinson (defendants) to establish her rights in property Earl and Alice owned but on which Ann and Wylie had built, improved, and maintained a house, with no written agreement transferring title. Ann argued Earl and Alice would be unjustly enriched if they kept the improved property without compensating her, and the trial court agreed, awarding her half the improvements' value (minus land value, after accounting for a loan) and also attaching a lien on the property for Wylie's separate child-support debts to Ann, even though Wylie himself disclaimed any interest in the property. Earl and Alice appealed, arguing unjust enrichment shouldn't apply since they never asked Ann and Wylie to make the improvements.
Whether a party who improves property with the owner's permission, even if not at the owner's request, may be entitled to an equitable lien on the property.