Tom Growney Equipment, Inc. v. Ansley
888 P.2d 992, 119 N.M. 110 (1994)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A party who performs services on a chattel at the request of a third party, without the owner's knowledge or authorization, cannot recover in restitution from the owner for unjust enrichment because doing so would infringe upon the owner's fundamental right of free choice regarding their property.
Facts:
- Jim Ansley (Owner) sold a backhoe loader on credit to Charles Edwards, retaining a security interest which he did not record.
- In November 1991, Edwards took the backhoe to Tom Growney Equipment, Inc. (Repairer) for repairs.
- Repairer, believing Edwards owned the backhoe free of any liens, performed the repairs.
- Repairer was unaware of Owner's security interest, and Owner was unaware of the services being provided by Repairer.
- Repairer released the backhoe back to Edwards in exchange for a promissory note for the cost of repairs.
- Subsequently, Edwards defaulted on his obligations to both Owner and Repairer.
- In March 1992, Owner repossessed the repaired backhoe from Edwards.
Procedural Posture:
- Tom Growney Equipment, Inc. (Repairer) sued both Charles Edwards and Jim Ansley (Owner) in district court.
- Repairer and Owner filed cross-motions for summary judgment against each other.
- The district court granted summary judgment against Repairer on its claims for open account and lien against Owner.
- The district court granted summary judgment in favor of Repairer on its claim for quantum meruit (restitution) against Owner for $7,002.53.
- Owner, as appellant, appealed the district court's judgment on the quantum meruit claim to the Court of Appeals of New Mexico.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does an equipment repair shop have a claim for restitution, based on a theory of unjust enrichment, against a property's owner for the value of repairs performed at the request of a third party in possession, when the owner neither authorized nor had knowledge of the repairs?
Opinions:
Majority - Bosson, Judge
No. A repair shop does not have a claim for restitution against an owner for unauthorized repairs because any enrichment is not unjust. The court adopted the 'orthodox view' which prioritizes the owner's fundamental right of free choice—the right to decide whether their property should be repaired, by whom, and at what cost. Forcing an owner to pay for unsolicited and unknown services would violate this right of self-determination. While the Owner was enriched by the repairs, the enrichment is not legally considered 'unjust' under these circumstances. Furthermore, the Repairer had a statutory mechanic's lien and could have retained possession of the backhoe until paid, but it voluntarily relinquished this security by accepting a promissory note from Edwards and chose to look to Edwards for payment.
Analysis:
This decision establishes the prevailing common law rule in New Mexico regarding claims of unjust enrichment for unauthorized improvements to chattels. It solidifies the principle that an owner's autonomy and right to control their property outweighs a service provider's claim for restitution when the services were unsolicited and unknown. The ruling clarifies that enrichment alone is insufficient; the enrichment must be 'unjust,' and it is not unjust when compelling payment would vitiate the owner's right of choice. This precedent serves as a clear warning to service providers that they bear the risk of nonpayment when they fail to verify ownership or secure their interests, for instance, by retaining possession under a mechanic's lien.
