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Housewright v. Vinyard, Not Reported in N.E.2d, 2013 IL App (3d) 120666-U, 2013 WL 4000432

Facts

Adam Housewright filed a complaint against Kylee Vinyard seeking to enforce a mechanics lien and other relief based on an alleged breach of an implied agreement. The dispute arose after Housewright provided labor and materials for remodeling Vinyard's home, which he claimed entitled him to compensation. Vinyard countered that no contract existed and alleged fraud against Housewright. The couple had a complicated relationship, including a broken engagement and shared ownership of the home, which they purchased in Vinyard's name.

On April 25, 2011, Housewright filed a three-count complaint seeking to enforce a mechanics lien and also requesting other relief based on quantum meruit due to the property owner's breach of an implied agreement.

Issue

Did the trial court err in granting a directed finding in favor of Vinyard and denying Housewright's claims for a mechanics lien and a gift in contemplation of marriage?

Housewright argues that the trial court erred by granting Vinyard's motion for a directed finding.

Rule

A directed finding is appropriate when the plaintiff fails to present a prima facie case, which requires evidence on every element essential to the cause of action. Additionally, gifts in contemplation of marriage are conditioned on the subsequent marriage of the parties.

A plaintiff establishes a prima facie case by proffering at least ‘some evidence on every element essential to the [plaintiff's underlying] cause of action.’

Analysis

The court applied the two-prong analysis to determine whether Housewright presented a prima facie case. It found that Housewright's claims did not meet the legal requirements for a mechanics lien or a gift in contemplation of marriage, as he failed to provide evidence of a valid contract and the contributions were deemed gifts. The court concluded that the improvements made to the property were fixtures that could not be returned, supporting the finding that Housewright was not entitled to compensation.

The record indicates that the court properly employed the two-prong review described in Sherman. In its ruling, the court first determined that there was not a basis in existing law for Housewright's gift in contemplation of marriage claim.

Conclusion

The trial court did not err in granting a directed finding for Vinyard, affirming that Housewright's claims were without merit. The case was remanded to allow Vinyard to present evidence for her counterclaim.

We conclude the trial court did not err when it granted a directed finding for Vinyard regarding the gift in contemplation of marriage claim.

Who won?

Kylee Vinyard prevailed in the case because the court found that Housewright failed to establish a prima facie case for his claims, determining that his contributions were gifts rather than compensable labor.

We affirm in part and remand.

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