James Tallichet v. Jackson Hole Community Radio, Inc. (a/k/a KHOL)

Summary

The Wyoming Supreme Court affirmed summary judgment for Jackson Hole Community Radio, Inc. in James Tallichet’s claims seeking repayment of funds he alleged were loans to the nonprofit radio station. The court held that the statute of frauds barred the breach-of-implied-contract claim because the alleged oral loan agreement was not sufficiently definite and no exception for partial or full performance applied. The court held that the statute of frauds does not bar unjust enrichment claims in Wyoming but concluded Tallichet failed to show that JHCR was reasonably notified, when the funds were conveyed, that he expected repayment.

Holdings

1. The alleged oral loan agreement fell within Wyoming's statute of frauds and could not support Tallichet's breach-of-implied-contract claim because it lacked a writing and the alleged agreement's essential terms were not sufficiently definite.
2. Tallichet failed to establish the partial- or full-performance exception because the alleged oral loan agreement was not just and certain.
3. The statute of frauds does not bar an unjust-enrichment claim in Wyoming.
4. Tallichet failed to establish the fourth element of unjust enrichment because the circumstances did not reasonably notify JHCR, when it received the contributions, that Tallichet expected repayment.

Questions Presented

1. Whether the district court erred in granting summary judgment against Tallichet on his breach-of-implied-contract claim based on the statute of frauds.
2. Whether the district court erred in granting summary judgment against Tallichet on his unjust-enrichment claim.

Disposition

affirmed