AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• The parties, an unmarried couple, cohabited from 2005 to 2015. During their cohabitation, the Defendant financially supported them, while the Plaintiff performed homemaking services and claimed to have contributed to the formation and operation of Defendant's businesses, Ingram Professional Services, Inc. and IPS Energy (collectively, IPS). The Plaintiff alleges that there was an agreement to start the business together, with her receiving half-ownership in exchange for her contributions. The Defendant, however, denies any agreement to share ownership of the business, characterizing the Plaintiff's contributions as minimal and stating that she was employed by IPS for less than a year. The parties separated in late 2015, leading to the Plaintiff filing a lawsuit against the Defendant for various claims, including breach of contract and unjust enrichment (paras 2, 12).

Procedural History

• District Court of Lea County: Summary judgment in favor of Defendant, ruling that Plaintiff failed to provide material issues of fact pursuant to Merrill v. Davis, 1983-NMSC-070, ¶¶ 6-9.

Parties' Submissions

• Plaintiff: Argued that the district court erred by viewing the case as a common law marriage matter instead of considering the business arrangements between the parties. Claimed to have agreed with the Defendant to start the business together, in exchange for half-ownership, and performed administrative duties and homemaking services for the Defendant (para 1).
• Defendant: Denied that there was an agreement to share ownership of the business, characterized Plaintiff’s contributions as minimal, and stated that Plaintiff was only an IPS employee for less than a year. Asserted that all IPS assets are titled exclusively in Defendant’s name, and raised all initial capital to start the business (paras 2, 8).

Legal Issues

• Whether the district court erred in granting summary judgment on the Plaintiff's breach of contract claim based on conflicting evidence regarding the existence of the contract.
• Whether the Plaintiff established a genuine issue of fact regarding unjust enrichment from her professional services for IPS and homemaking services.
• Whether the Plaintiff's claims for promissory estoppel, negligent misrepresentation, common law fraud, constructive fraud, conversion, prima facie tort, and breach of implied covenant of good faith and fair dealing were properly dismissed on summary judgment.

Disposition

• Summary judgment affirmed for all claims except unjust enrichment, which was reversed in part for limited review regarding any uncompensated administrative services Plaintiff provided to IPS between 2012 and 2015 (para 29).

Reasons

• The Court, consisting of Judges Bogardus, Medina, and Yohalem, held that the Plaintiff failed to provide evidence of an express agreement to share ownership of IPS, which is required under Merrill v. Davis to jointly own property as unmarried cohabitants. The Court found that the Plaintiff's evidence suggested an implied agreement, which is insufficient under Merrill. For the unjust enrichment claim, the Court found that Plaintiff presented sufficient evidence to allow reasonable minds to differ on whether Defendant received unjust benefits from Plaintiff’s professional services, thus reversing and remanding this claim for limited review. The Court affirmed summary judgment on the remaining claims, concluding that the Plaintiff failed to raise genuine issues of material fact necessary to support her claims (paras 3-28).