Kunde v. Estate of Arthur D. Bowman
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The Supreme Court affirmed in part and reversed in part the judgment of the district court dismissing Plaintiff’s unjust enrichment, quantum meruit, and promissory estoppel claims, holding that the district court erred in granting Defendants’ motion for summary judgment on the promissory estoppel claim.
Plaintiff, a farmer, sued Defendants, his neighbor’s heirs, claiming that he and the decedent entered into an option contract to purchase farmland that Plaintiff leased from he decedent and upon which Plaintiff had made substantial improvements. After the farm was sold, Plaintiff brought this action claiming that Defendants breached an option contract to sell him the property. Alternatively, Plaintiff alleged various equitable theories of promissory estoppel, quantum meruit, and unjust enrichment. A jury found in favor of Plaintiff on his contract claim, but the district court granted Defendants’ motion for directed verdict and refused to order a new trial on Plaintiff’s alternative equitable theories. The court of appeals remanded the case for further proceedings on the equitable claims. On remand, the district court granted Defendants’ motion for summary judgment on the remaining equitable claims. The Supreme Court reversed in part, holding that Plaintiff’s promissory estoppel claim survived summary judgment.
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