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Contracts – Unjust enrichment – quantum meruit

Contracts
Unjust enrichment; quantum meruit

Where the district court made inconsistent factual findings unsupported by the evidence, the judgment must be reversed.

“Though the court made two factual findings that might link this evidence to a conclusion that Lindquist was entitled to an equitable remedy, both findings lack sufficient support in the evidence. The first was that Middleton fired Miller ‘just as many of his cost-cutting and sales-boosting strategies were beginning to show results.’ Lindquist II, 665 F. Supp. 2d at 1020. The only evidence to support this finding was Miller’s testimony and report, and we have already explained why it was error to credit this evidence. Second, the court found that the primary cause for the breakdown in the parties’ relationship—Lindquist’s failure to come forward with the contemplated cash infusion—was really Middleton’s fault. The court thought that Middleton’s need for new capital was secondary to its need for management skills. This inference was based on a short line of questioning at trial in which Dave Hudson testified that Middleton had previously considered and rejected an arrangement with Geiger Group, a Wisconsin dealership that might have been able to provide the needed cash infusion but not a general manager. But Dave Hudson did not emphasize the lack of a general manager as the reason he ended negotiations with Geiger. He explained instead that his discussions with Geiger did not proceed beyond the preliminary stage because he did not feel comfortable with Geiger’s people. Accordingly, his testimony does not support the court’s finding that Middleton’s need for cash was secondary to its need for management service. If anything, his testimony establishes that Middleton’s capital and management needs were equally important and that investment capital was central to its pursuit of a relationship with another dealership.”

Reversed and Remanded.

09-3883 Lindquist Ford, Inc., v. Middleton Motors, Inc.

Appeal from the United States District Court for the Western District of Wisconsin, Crabb, J., Sykes, J.

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