South County Post & Beam, Inc. v. Brian T. McMahon et al.

Summary

The Rhode Island Supreme Court reviewed a dispute between property owners and a subcontractor over unpaid construction work. The Court affirmed a judgment awarding the subcontractor $41,549.45 under unjust enrichment and quantum meruit principles, holding that the absence of an adequate remedy at law was not an independent bar to recovery. It vacated and remanded the order taxing the subcontractor’s expert-witness fee as a recoverable cost.

Holdings

1. The absence of an adequate remedy at law is not a required element of a standalone claim for unjust enrichment or quantum meruit seeking monetary compensation. It is merely one factor in the fact-specific balancing of equities under the third element of the claim.
2. The expert-witness fee was not properly taxable as a cost because Rhode Island General Laws § 9-17-22 specifically prohibits expert fees as costs except as provided by the Rules of Evidence.

Questions Presented

1. Whether the Superior Court properly awarded damages for unjust enrichment when the plaintiff had a contractual relationship with the general contractor and had not shown the absence of an adequate remedy at law.
2. Whether the Superior Court properly included the plaintiff's expert-witness fee as a taxable cost.

Disposition

reversed_and_remanded