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Mitchell v. Moore | 729 A.2d 1200 (1999)

Generally, someone who benefits from another person’s services must compensate that other person if retaining the benefit without paying for its value would be unjust. But this principle doesn’t apply if an individual provides services without expecting payment. In Mitchell versus Moore, the Pennsylvania Superior Court considered whether services performed between members of a cohabitating couple require compensation to prevent injustice.

Soon after meeting in nineteen eighty, Thomas Mitchell and William Moore began a romantic relationship. The following year, Mitchell accepted Moore’s invitation to move into Moore’s farmhouse. Mitchell didn’t pay rent but helped maintain Moore’s house and farm by performing a wide variety of chores. Mitchell also took care of the farm animals and assisted with Moore’s businesses breeding birds and sheep. In nineteen ninety, Mitchell began a graduate program that required a significant time commitment. As a result, Mitchell couldn’t continue maintaining the farm or managing Moore’s bird and sheep businesses. The couple’s relationship deteriorated, and when they ultimately broke up in nineteen ninety four, Mitchell moved out of Moore’s house.

Mitchell brought an action against Moore, seeking restitution for the services he performed during the thirteen years the couple lived together. Mitchell alleged that Moore promised him compensation for maintaining and managing the farm and assisting with Moore’s businesses. Moore filed a counterclaim, seeking compensation for rent, utilities, and taxes for the years Mitchell lived in Moore’s house. The trial court found in favor of Mitchell on the basis of unjust enrichment and against Moore on his counterclaim. Moore appealed to the Pennsylvania Superior Court.

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