Collins v. Lewis

Supreme Court of Connecticut
111 Conn. 299, 149 A. 668 (1930)

ELI5:

Rule of Law:

A contract implied in law, or quasi-contract, arises when one party renders services with an expectation of payment and the other party, knowing of these circumstances, accepts the benefit of those services.

Facts:

Charles Kinne possessed ten cows under a conditional sale contract with the legal owner, the defendant Lewis.
The plaintiff, a deputy sheriff, lawfully attached the ten cows while they were in Kinne's possession, believing them to be Kinne's property.
After the attachment, the plaintiff discovered that Lewis held legal title to the cows.
The plaintiff attempted to return the cows to Kinne, who had abandoned his interest in them and refused to take them back.
The plaintiff then made multiple offers to return the cows to Lewis, who refused to accept them 'at that time,' citing a lack of space.
The plaintiff's attorney formally notified Lewis by letter that the plaintiff was holding the cows for Lewis and expected to be compensated for their keep.
The plaintiff cared for the cows for 38 days at a farm.
After 38 days, Lewis met with the plaintiff, announced his intention to sell the cows, and subsequently sold them, taking possession from the plaintiff's caretaker and providing the plaintiff a receipt.

Procedural Posture:

The plaintiff, a deputy sheriff, sued the defendant, Lewis, in a trial court to recover the costs of boarding ten cows.
The trial court found the issues for the plaintiff, ruling that there was an implied promise on the part of Lewis to pay for the cows' board.
The trial court entered a judgment for the plaintiff in the amount of $190.
The defendant, Lewis, appealed the judgment to the Connecticut Supreme Court of Errors.

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Issue:

Does an implied contract to pay for the care of property arise when the property's owner, knowing that another person is caring for the property with an expectation of payment, repeatedly refuses to take possession but later accepts the benefit of that care by repossessing and selling the property?

Opinions:

Majority - Haines, J.

Yes, an implied contract to pay for the care of the property arises under these circumstances. A contract is implied in law where a plaintiff, without being requested to do so, renders services under circumstances indicating an expectation of payment, and the defendant, knowing of these circumstances, avails himself of the benefit of those services. Here, the plaintiff's initial attachment of Kinne's equitable interest in the cows was lawful. After Kinne abandoned his interest, the plaintiff's possession became that of an individual holding property for the true owner, Lewis. The plaintiff repeatedly tendered the cows to Lewis and expressly notified him that he expected payment for their care. By refusing to take the cows but later repossessing and selling them after 38 days of care, Lewis knowingly accepted the benefit of the plaintiff's services. This appropriation of the benefit, with knowledge that compensation was expected, created a legal obligation for Lewis to pay the reasonable value of the cows' care and keep.

Analysis:

This decision provides a clear illustration of a contract implied in law (quasi-contract), founded on the principle of preventing unjust enrichment. It establishes that a party's conduct, specifically the knowing acceptance of a benefit for which payment is expected, can create a legal obligation to pay even without an express agreement. The ruling clarifies that a property owner cannot strategically delay repossession while another party bears the cost of maintaining the property and then reap the benefits without compensating the caretaker. This precedent is significant in situations involving bailees, creditors, or law enforcement who find themselves in possession of another's property and must care for it before it is returned to the rightful owner.

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