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Real Property: Unjust Enrichment-Party Status

Staff Report//July 9, 2026//

Real Property: Unjust Enrichment-Party Status

Staff Report//July 9, 2026//

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Plaintiff appealed the trial court’s judgment in favor of John Miller III on his counterclaim for unjust enrichment, arguing that Miller was not a party to the lawsuit and failed to present sufficient evidence to prove that his payments supported an unjust enrichment claim.

Where Miller was not a party to the ejectment action because he was not the named defendant and had not moved to join or intervene in the action, the trial court erred in entering judgment in his favor on his unjust enrichment claim.

Judgment is vacated.

Hayes v. Miller (MLW No. 84945/Case No. ED113836 – 10 pages) (Missouri Court of Appeals, Eastern District, Lay, J.) Appealed from circuit court, St. Louis County, Lasater, J. (Richard E. Coughlin for appellant) (Herman L. Jimerson for respondent)

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