Frambach v. Dunihue
419 So.2d 1115 (1982)
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Rule of Law:
A person who contributes labor and materials to improve the property of another, but pays no part of the purchase price, is not entitled to an ownership interest through a constructive or resulting trust. The proper remedy to prevent unjust enrichment is an equitable lien for the value of the contributions that exceeds the value of any benefits received by the contributor.
Facts:
- Stanley H. Dunihue, a widower with seven children, and the Frambach family, with their four children, lived near each other.
- In September 1960, the two families began living together in the Frambachs' small home after riding out a hurricane together.
- Over the next nineteen years, Dunihue contributed significant labor and funds to substantially enlarge and improve the home to accommodate the combined families, which grew to include three adults and twelve children.
- The parties operated as a single family unit, pooling their earnings into common bank accounts managed by Mrs. Frambach, who paid all household bills.
- Both Dunihue and Mr. Frambach were employed, with Dunihue generally having a larger income.
- After nineteen years, once all of Dunihue's children had moved out, Mrs. Frambach abruptly ordered Dunihue to leave the home.
Procedural Posture:
- Stanley H. Dunihue filed suit against Paul and Allene Frambach in a Florida trial court, seeking to impose an equitable lien on their property.
- Dunihue alleged that the Frambachs had promised him a place to live for life in exchange for his work and that they would be unjustly enriched without compensation.
- The trial court found in favor of Dunihue, awarding him an undivided one-half interest in the property and declaring the parties tenants in common.
- The Frambachs (Appellants) appealed the trial court's judgment to the District Court of Appeal of Florida, Fifth District, challenging the award of an ownership interest to Dunihue (Appellee).
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Issue:
Is a person who contributes substantial labor and materials to improve another's real property, as part of a long-term communal living arrangement, entitled to an ownership interest in that property, or is their remedy limited to an equitable lien to prevent unjust enrichment?
Opinions:
Majority - Frank D. Upchurch, Jr.
No, a person who improves another's property without contributing to the purchase price is not entitled to an ownership interest; their remedy is limited to an equitable lien. A constructive or resulting trust, which creates an ownership interest, cannot be imposed in favor of a person who pays no part of the property's purchase price, even if they pay for substantial improvements. While a court of equity can prevent unjust enrichment, the proper remedy is to grant an equitable lien upon the property, not to compel a transfer of title. The trial court erred by treating the arrangement as a de facto marriage and awarding Dunihue a tenancy in common. The case must be remanded for the trial court to determine the value of Dunihue's contributions (labor, services, materials) and offset that by the value of the benefits he and his family received from the Frambachs over the nineteen years. If Dunihue's contributions exceed the benefits he received, an equitable lien for that net amount should be imposed on the property.
Analysis:
This case clarifies the critical distinction between an equitable lien and a constructive trust as remedies for unjust enrichment. It establishes that merely improving another's property, even in the context of a long-term, quasi-familial relationship with commingled funds, does not grant an ownership stake. The decision reinforces the traditional requirement that a resulting or constructive trust claim to title must be linked to contributing to the property's purchase price. For future cases involving non-marital cohabitation and property improvements, this ruling limits the remedy for the non-title-holding party to restitution for the net value of their contributions, rather than a share of the property's appreciated value as a co-owner.
