Anderson v. Copeland
1963 OK 34, 378 P.2d 1006, 1963 Okla. LEXIS 314 (1963)
Rule of Law:
When a sales contract is rescinded after the buyer has possessed and used the property, the law implies a quasi-contract requiring the buyer to pay the reasonable rental value of the property to prevent unjust enrichment.
Facts:
- Anderson orally agreed to purchase a used tractor from Copeland for $475.00.
- Anderson took possession of the tractor.
- For eleven days, Anderson attempted to borrow money to cover the purchase price but was unsuccessful.
- Anderson informed Copeland that he could not secure the funds.
- Copeland requested the return of the tractor.
- Anderson returned the tractor after having it in his possession for approximately two weeks.
- Both parties mutually agreed to rescind (cancel) the original sales contract.
- Anderson did not pay Copeland for the use of the tractor during the two weeks he possessed it.
Procedural Posture:
- Copeland sued Anderson in the District Court of Cotton County for the rental value of the tractor.
- The case was tried to a jury.
- The jury returned a verdict in favor of Copeland in the amount of $50.00.
- Anderson filed a motion for a new trial.
- The District Court overruled the motion for a new trial.
- Anderson appealed the judgment to the Supreme Court of Oklahoma.
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Issue:
Does the law impose a quasi-contractual obligation on a prospective buyer to pay the reasonable rental value for a tractor used during a failed sales transaction, despite the absence of an express rental agreement?
Opinions:
Majority - Per Curiam
Yes, the law implies a contract for the defendant to pay the reasonable rental value of the property to prevent unjust enrichment. The Court reasoned that once the sales contract was rescinded, the parties were returned to their original positions, except that Anderson had enjoyed the benefit of using the tractor for two weeks without payment. Citing Piggee v. Mercy Hospital, the Court explained that quasi-contracts are obligations created by law based on reason and justice, regardless of the parties' assent. The Court rejected Anderson's argument that an express contract (the sale) prevents an implied contract, noting that the subject matter differed: the express contract was for a sale, while the implied contract was for rental. Therefore, Anderson was liable for the value of the use of the tractor.
Analysis:
This case illustrates the equitable safety net of 'quasi-contract' or 'contract implied in law.' It clarifies that the existence of a failed or rescinded express contract (like a sale) does not bar a claim for unjust enrichment regarding a different aspect of the transaction (like usage/rental). The court draws a sharp distinction between contracts implied in fact (based on intent) and contracts implied in law (imposed by the court for justice). For law students, this demonstrates that even where a specific deal fails, the law may still compel payment for benefits received to prevent one party from gaining an unfair advantage at the expense of another.
