Navigating Property Disputes: Partition Action and Unjust Enrichment

Imagine a scenario where two unmarried individuals purchase a home, but the property title bears only one name. What happens when the relationship ends? Who retains ownership of the house?

When both parties are listed on the title, the situation is straightforward: they share ownership. Should a dispute arise, a Partition Action can be pursued legally, where the court assesses their respective rights and contributions to the property's acquisition and preservation, potentially ordering its sale.

But what happens if only one party is on the title? Legally, the title determines ownership, and most agreements involving real property need to be in writing, as per the statute of frauds (Minn Stat. Sec. 513). While the statute restricts actions based on a promise to marry, it doesn't prevent claims for unjust enrichment or promissory estoppel.

Consider the Minnesota case of Patricia Lloyd and Todd Anderson around 2000. Patricia owned a house where Todd moved in, paid the mortgage, and made home improvements, operating his business from there. Although engaged, their relationship was tumultuous, and at times Patty insisted she wouldn't marry Todd. When Todd later sued for breach of contract and unjust enrichment, his claim for damages based on a marriage promise was nullified due to Minnesota Statutes Sec. 553.01-03 abolishing such claims.

However, Todd's claims for unjust enrichment and promissory estoppel remain valid. He must show that Patricia was unjustly enriched by his contributions and any promises independent of marriage, such as assurances of permanent residence, were made. The court remanded the case for further proceedings.