Curtis v. Becker

LANSING, Judge,

specially concurring.

I concur in the lead opinion. I write separately because, in my view, the result would be the same even without application of the clean hands doctrine upon which the lead opinion relies. I conclude that even if Curtis had been more forthcoming in his dealings with the City of Twin Falls, he would not be entitled to recover because he acted officiously in installing unwanted physical improvements on the Beckers’ property and because the benefit to the Beckers was incidental to Curtis’s pursuit of his own financial interest.

As the lead opinion notes, the officious intermeddler doctrine precludes recovery for unjust enrichment by one who has officiously thrust a benefit upon another. This doctrine is explained in the RESTATEMENT OF RESTITUTION § 2, cmt. A (1937) as follows:

Officiousness means interference in the affairs of others not justified by the circumstances under which the interference takes place. Policy ordinarily requires that a person who has conferred a benefit either by way of giving another services or by adding to the value of his land or by paying his debt or even by transferring property to him should not be permitted to require the other to pay therefor, unless the one conferring the benefit had a valid reason for so doing. A person is not required to deal with another unless he so desires and, ordinarily, a person should not be required to become an obligor unless he so desires.
*385... [W]here a person has officiously conferred a benefit upon another, the other is enriched but is not considered to be unjustly enriched. The rule denying restitution to officious persons has the effect of penalizing those who thrust benefits upon others and protecting persons who have had benefits thrust upon them.

Idaho has recognized the officious intermed-dler doctrine. Chinchurreta v. Evergreen Management, Inc., 117 Idaho 591, 593, 790 P.2d 372, 374 (Ct.App.1989). In addition, under Idaho law, recovery for unjust enrichment is not available if the benefit to another was created incidentally in the plaintiffs pursuit of his own financial advantage. Hettinga v. Sybrandy, 126 Idaho 467, 471, 886 P.2d 772, 776 (1994).

In the present case, Curtis did not obtain the Beckers’ consent before beginning work on their land. The trial testimony is in conflict as to when the Beckers first told Curtis that they did not want the improvements on their property, but it is uncontroverted that before the improvements were completed, Curtis knew very well that the Beckers objected to the work. While the construction was in progress, the Beckers’ attorney sent a letter to Curtis stating that they did not wish to have the lots developed. Moreover, after the work had begun without their consent, the Beckers barricaded the property to prevent its continuation, but Curtis took down the barricades and resumed his activity.

Curtis installed the improvements over the Beckers’ objection so he would be able to comply with City’s requirements for the subdivision of his own adjacent property and would be able thereby to realize profits from the sale of his lots. It is inaccurate, however, for Curtis to characterize his position as being “forced” by the City to improve Beck-ers’ lots at their expense and over their protest. If Curtis could not obtain the Beck-ers’ authorization to develop their lots at their expense, he had several choices: he could have sought the Beckers’ agreement to let him install the improvements without cost to the Beckers; or he could have negotiated to purchase the lots from them at whatever price the Beckers might require; or he could have gone back to the City to try to negotiate changes to the Improvement Agreement; or he could have simply abandoned his plan to develop the subdivision. Curtis did none of these but instead forged ahead, forcing upon the Beckers changes to their lots that they did not want and for which they never agreed to pay.

Curtis gives no satisfactory explanation as to why his choice as to how he wanted to use his property should take legal precedence over how the Beckers chose to use theirs. I know of no rule of law that, under the circumstances presented here, allows one party to alter the property of another and impose upon that property owner an uninvited financial burden merely so that the first party can use his own property as he deems most desirable and profitable.

The actions that Curtis took on the Beck-ers’ property were those of an officious in-termeddler, and were taken for Curtis’s own financial advantage. The benefit received by the Beckers therefore was not “unjust,” and Curtis is not entitled to compensation.

PERRY, J., concurs both in the lead opinion and in Judge LANSING’s concurring opinion.