Bailey v. West
249 A.2d 414, 105 R.I. 61, 1969 R.I. LEXIS 718 (1969)
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Rule of Law:
A person who confers a benefit upon another without being requested to do so is considered a 'volunteer' and is not entitled to compensation under a quasi-contract theory, especially when the person knows there is a controversy regarding the subject of the benefit.
Facts:
- In April 1962, defendant West purchased a race horse, 'Bascom's Folly,' from Dr. Strauss.
- Upon the horse's arrival, West's trainer discovered it was lame and, per West's instructions, attempted to ship it back to Dr. Strauss.
- On May 3, 1962, Dr. Strauss refused to accept the horse's return.
- The van driver, Kelly, was instructed by West's trainer that West would not be responsible for the horse's board at any farm.
- Kelly then brought the horse to the farm of plaintiff Bailey.
- Bailey accepted the horse for boarding, knowing from the bill of lading and conversation with Kelly that there was a dispute over its ownership.
- Bailey cared for the horse from May 3, 1962, through July 3, 1966, and sent regular bills to West.
- Upon receiving the first bill, West immediately returned it to Bailey with a note disclaiming ownership and responsibility for the horse's care.
Procedural Posture:
- Plaintiff Bailey filed a civil action against defendant West in the Rhode Island Superior Court (trial court).
- The case was tried before a superior court justice sitting without a jury.
- The trial court found for the plaintiff Bailey, awarding him judgment for the cost of boarding the horse for five months, plus some expenses.
- Plaintiff Bailey appealed the judgment to the Supreme Court of Rhode Island, and defendant West filed a cross-appeal.
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Issue:
Does a person who provides services to care for property, knowing there is a dispute over its ownership and without a request from the owner, create a quasi-contractual obligation for the owner to pay for those services?
Opinions:
Majority - Paolino, J.
No, a quasi-contractual obligation is not created under these circumstances. The court held that there was no contract implied in fact because there was no mutual agreement or intent to promise between Bailey and West. Furthermore, no quasi-contract (contract implied in law) existed because Bailey acted as a 'volunteer.' A quasi-contract requires that it would be inequitable for the defendant to retain a benefit without payment, but this principle does not apply to a benefit officiously conferred. Bailey knew of the ownership controversy when he accepted the horse and could not have reasonably expected payment from West. West did not acquiesce in the benefit; instead, he immediately disclaimed responsibility upon receiving the first bill. Therefore, Bailey was a mere volunteer who provided services at his own risk and cannot recover for them.
Analysis:
This case provides a clear distinction between a contract implied in fact, which requires a mutual intent to contract, and a quasi-contract, which is an equitable remedy to prevent unjust enrichment. The decision reinforces the 'officious intermeddler' or 'volunteer' doctrine as a significant limitation on quasi-contractual recovery. It establishes that one cannot impose a contractual obligation on another by knowingly conferring an unsolicited benefit, particularly when aware of a dispute that makes the other party's acceptance of the benefit uncertain or unwilling. This precedent protects individuals from being forced to pay for services they did not request and explicitly rejected.
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