Birchwood Land Company, Inc. v. Judith J. Krizan

Summary

The court affirmed dismissal of Birchwood’s unjust-enrichment claim arising from road, utility, and infrastructure improvements that increased the value and developability of Krizan’s landlocked property. Adopting the applicable restitution principles, the court held that voluntary improvements undertaken for the claimant’s own benefit are not recoverable absent circumstances such as mistake, fraud, or compulsion, and that an easement supports restitution for necessary repairs or maintenance, not unrequested improvements. No separate opinions were presented.