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Keywords

contractplaintiffdefendantunjust enrichment
contractplaintiffdefendantunjust enrichment

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Watts v. Watts

Facts

The parties' 12-year nonmarital cohabitation relationship produced 2 children. The plaintiff alleged that during their relationship, she contributed significantly to the household and business, including childcare, homemaking, and working in the defendant's business. The plaintiff claimed that the defendant had made representations that she would share in the wealth accumulated during their relationship, and after their relationship ended, he refused to share the property they had jointly acquired.

The parties' 12-year nonmarital cohabitation relationship produced 2 children. The plaintiff alleged that during their relationship, she contributed significantly to the household and business, including childcare, homemaking, and working in the defendant's business. The plaintiff claimed that the defendant had made representations that she would share in the wealth accumulated during their relationship, and after their relationship ended, he refused to share the property they had jointly acquired.

Issue

Did the plaintiff state a claim upon which relief could be granted for property division and accounting based on her nonmarital cohabitation with the defendant?

Did the plaintiff state a claim upon which relief could be granted for property division and accounting based on her nonmarital cohabitation with the defendant?

Rule

The court held that nonmarital cohabitation does not preclude a party from seeking judicial relief for property disputes, and that claims can be based on contract, unjust enrichment, or partition.

The court held that nonmarital cohabitation does not preclude a party from seeking judicial relief for property disputes, and that claims can be based on contract, unjust enrichment, or partition.

Analysis

The court analyzed the plaintiff's claims and determined that she had sufficiently alleged facts that could support a claim for relief under various legal theories. The court noted that the dismissal by the circuit court was premature, as the plaintiff's allegations, if proven, could establish a right to an equitable division of property accumulated during the cohabitation.

The court analyzed the plaintiff's claims and determined that she had sufficiently alleged facts that could support a claim for relief under various legal theories. The court noted that the dismissal by the circuit court was premature, as the plaintiff's allegations, if proven, could establish a right to an equitable division of property accumulated during the cohabitation.

Conclusion

The judgment that dismissed the female's action against the male for an accounting and a share of the personal and business assets accumulated during the parties' unmarried cohabitation relationship was reversed.

The judgment that dismissed the female's action against the male for an accounting and a share of the personal and business assets accumulated during the parties' unmarried cohabitation relationship was reversed.

Who won?

The plaintiff, Sue Ann Watts, prevailed because the court found that she had stated a claim for which relief could be granted based on her contributions and the nature of the relationship.

The plaintiff, Sue Ann Watts, prevailed because the court found that she had stated a claim for which relief could be granted based on her contributions and the nature of the relationship.

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