Thompson Metal Fab, Inc. v. Venture Global Plaquemines LNG, LLC and KZJV, LLC

Summary

The United States District Court for the Eastern District of Louisiana granted Venture Global Plaquemines LNG, LLC’s motion to dismiss Thompson Metal Fab, Inc.’s unjust enrichment claim. The court held that the alleged enrichment was justified by the contract between Venture and KZJV governing the procurement of fabricated steel, and therefore could not support an unjust enrichment claim under Louisiana law.

Holdings

1. Thompson failed to state an unjust enrichment claim because Venture's alleged enrichment resulted from the valid Venture-KZJV contract, which supplied a cause or justification for the enrichment.
2. Thompson could not proceed on unjust enrichment merely by alleging that the contract did not cover additional job-related expenses or that it performed work beyond its contractual promises.

Questions Presented

1. Whether Thompson's unjust enrichment claim against Venture survived a Rule 12(b)(6) motion where the alleged enrichment resulted from a contract between Venture and KZJV.
2. Whether Thompson could maintain unjust enrichment based on additional work and expenses allegedly exceeding the value or scope of the steel-supply arrangement.

Disposition

dismissed