Sparks v. Gustafson – Case Brief
Sparks v. Gustafson, 750 P.2d 338 (Alaska 1988).
Facts: Gustafson (D) was a friend and business associate of Sparks Sr. and managed the Nome Center for Sparks without compensation until Sparks’ death in 1981. Gustafson continued to collect rent without approval from Sparks Jr. (P). Gustafson did not request and did not receive compensation for his services and did not inform Sparks Jr. of operating expenses that he paid out of his own pocket.
Gustafson discussed purchasing the Nome Center from Sparks Jr. but the parties never reached an agreement. Sparks Jr. sold the Nome Center to a third party in 1983 and P sued D for breach of an oral agreement to sell the building to him. D also claimed a statutory or equitable lien on the building for his expenses related to the Nome Center. At trial, the court entered judgment in favor of P and ordered the estate to pay $65,706 for services and improvements.
Issue: Does unjust enrichment apply when a party keeps a benefit that was given gratuitously without expectation of payment, if the benefit was not the sort which one would ordinarily expect to receive from a friend as a mere gratuity?
Holding and Rule: Yes. P worked five hours per day and paid bills out of his own pocket, collected rents, paid utilities, solicited new tenants, and performed general and other maintenance when it was required. The court held that P was entitled to compensation because the services that P performed for the Estate were not the sort which one would ordinarily expect to receive from a friend as a mere gratuity.