Summary
The United States District Court for the Eastern District of Washington issued an order denying the plaintiffs' motion to dismiss the defendants' counterclaim for unjust enrichment. Applying Federal Rule of Civil Procedure 12(b)(6), the court evaluated whether the claim was barred by Washington's three-year statute of limitations. Accepting the defendants' allegations that the original downpayment and gold were repurposed for a future joint venture, the court concluded the cause of action accrued later under the discovery rule and thus survived dismissal.
Topics
Practice areas
Questions Presented
- Whether the defendants' counterclaim for unjust enrichment is time‑barred under RCW 4.16.080(3).
- Whether the plaintiffs' allegations survive a Rule 12(b)(6) motion to dismiss.
Holdings
- The court declined to dismiss the counterclaim, finding the claim plausible and not time‑barred because the unjust enrichment may have arisen when the parties redefined the transaction during the later business venture.
- The motion to dismiss is denied because the plaintiffs provide sufficient factual content to make the counterclaim plausible.
Key quotations
“A 12(b)(6) motion will be denied if the plaintiff alleges “sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)).” (-)
“The discovery rule does not require knowledge of the existence of a legal cause of action itself, but merely knowledge of the facts necessary to establish the elements of the claim. Douchette v. Bethel Sch. Dist. No. 403, 117 Wash.2d 805, 814 (1991).” (-)
Factual background
Defendants allege that in 2019 Boyd received a $268,000 down‑payment to build a laundromat and 30 ounces of gold. The laundromat was never built, and the parties later pursued an El Salvador‑based car resale venture. Defendants claim the down‑payment and gold constitute unjust enrichment that became actionable when the parties redefined the transaction during the later venture.
Procedural history
The court previously granted plaintiffs' motion to dismiss the complaint and allowed defendants to amend their counterclaim. Plaintiffs subsequently moved to dismiss the amended counterclaim; the court denied that motion.