This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The Defendant sold a backhoe loader on credit to a third party, retaining a security interest but failing to record it. The third party later took the backhoe to the Plaintiff, an equipment repair shop, for repairs. The Plaintiff performed the repairs and released the backhoe in exchange for a promissory note, unaware of the Defendant's security interest. The third party defaulted on both obligations, and the Defendant repossessed the backhoe. The Plaintiff sought restitution for the repair costs, claiming unjust enrichment (paras 2-3).
Procedural History
- District Court of Bernalillo County: Entered summary judgment against the Plaintiff on claims of open account and lien but ruled in favor of the Plaintiff on a quantum meruit claim for $7,002.53 (para 3).
Parties' Submissions
- Plaintiff (Repairer): Argued that the Defendant was unjustly enriched by the repairs performed on the backhoe and sought restitution under a theory of quantum meruit (paras 4-5).
- Defendant (Owner): Contended that restitution was not warranted as the repairs were unsolicited and performed without the Defendant's knowledge or consent, emphasizing the right to choose whether to accept or pay for such services (paras 8-9).
Legal Issues
- Whether an equipment repair shop can recover in restitution for repairs performed without the owner's authorization or knowledge (para 1).
Disposition
- The Court of Appeals reversed the district court's grant of summary judgment in favor of the Plaintiff and directed judgment in favor of the Defendant (para 13).
Reasons
Per Bosson J. (Minzner CJ. and Donnelly J. concurring):
The Court held that restitution was not available because the Defendant did not authorize or have knowledge of the repairs, and compelling payment would infringe on the Defendant's right to choose whether to accept such services. The Court emphasized that unjust enrichment requires the enrichment to be "unjust," which was not the case here. The Plaintiff had the option to retain a mechanic's lien on the backhoe but waived it by releasing the vehicle to the third party. The Court adopted the majority rule from other jurisdictions, which denies restitution in similar circumstances, and found that the Plaintiff's claim was barred under these principles (paras 8-12).