Contracts : Breach Of Contract – Unjust Enrichment – Standing

Where the widow of a pastor brought claims including conversion, unjust enrichment, breach of contract and failure to produce documents against their church employer after his death, the trial court properly granted summary judgment to the church on the conversion, unjust enrichment and breach of contract claims because the plaintiff did not have standing to pursue the claims since she did not show that she was judicially determined to be his heir, but the court erred in granting summary judgment to the church on claims of failure to produce documents and an ultra vires act because a genuine issue of material fact remained as to the plaintiff’s status as a member of the church at the time she made her request and filed her petition.

Judgment is affirmed in part; reversed in part.

White v. Emmanuel Baptist Church (MLW No. 70591/Case No. WD79999 – 22 pages) (Missouri Court of Appeals, Western District, Martin, J.) Appealed from circuit court, Jackson County, Midkiff, J. (Taylor Fields, Kansas City, Missouri, for appellant) (Sherwin L. Epstein, Leawood, Kansas, for respondent).

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