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Keywords

appealtrialunjust enrichment
appealtrialunjust enrichment

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Troxler v. Breaux, 105 So.3d 944, 12-330 (La.App. 5 Cir. 11/27/12)

Facts

Depp Troxler and Melinda Breaux cohabited in a house purchased solely by Breaux from December 2008 until October 2009. During this time, Troxler deposited a total of $33,219.35 into a joint checking account they maintained, which was used to pay household expenses, including the mortgage. Troxler claimed he purchased various items for the house, but he did not have receipts to substantiate his claims. Breaux admitted to owing Troxler $10,000 and acknowledged that he could retrieve certain items he purchased for the home.

Depp Troxler and Melinda Breaux cohabited in a house purchased solely by Breaux from December 2008 until October 2009.

Issue

Did the trial court err in finding that Troxler failed to establish a claim for unjust enrichment and in its determination of the amounts paid towards household expenses?

Did the trial court err in finding that Troxler failed to establish a claim for unjust enrichment and in its determination of the amounts paid towards household expenses?

Rule

Under Louisiana law, the elements of a claim for unjust enrichment include: (1) an enrichment; (2) an impoverishment; (3) a connection between the enrichment and the impoverishment; (4) an absence of justification or cause for the enrichment and impoverishment; and (5) no other available remedy at law.

Under Louisiana law, the elements of a claim for unjust enrichment include: (1) an enrichment; (2) an impoverishment; (3) a connection between the enrichment and the impoverishment; (4) an absence of justification or cause for the enrichment and impoverishment; and (5) no other available remedy at law.

Analysis

The court found that Troxler did not prove the elements of unjust enrichment, as both parties contributed to the joint account and the funds were used for household expenses. The court noted that while Troxler was not present at the home every day, he allowed Breaux to use his funds for necessary expenses. The trial court's findings regarding the amounts paid and the nature of the contributions were deemed reasonable and supported by the record.

The court found that Troxler did not prove the elements of unjust enrichment, as both parties contributed to the joint account and the funds were used for household expenses.

Conclusion

The Court of Appeal affirmed the trial court's judgment, concluding that Troxler's claims were not substantiated and that the trial court's findings were reasonable.

The Court of Appeal affirmed the trial court's judgment, concluding that Troxler's claims were not substantiated and that the trial court's findings were reasonable.

Who won?

Melinda Breaux prevailed in the case because the court found that Troxler failed to establish his claims for unjust enrichment and that the trial court's findings were supported by the evidence.

Melinda Breaux prevailed in the case because the court found that Troxler failed to establish his claims for unjust enrichment and that the trial court's findings were supported by the evidence.

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