When does a statute of limitations commence on an Unjust Enrichment Claim?

In April of this year, Florida’s Fourth District Court of Appeals was confronted with the issue of when does the statute of limitations commence running on the four year statute of limitations applicable to an unjust enrichment claim. The court held that the statutes of limitations on unjust enrichment or quantum meruit claims generally begin to run upon the occurrence of the event that created the uncompensated benefit in the defendant, that is, the plaintiff performed the labor that benefited the defendant or the defendant obtained the subject property or goods.

Beltran v. Vincent P. Miraglia, M.D., P.A., 38 Fla. L. Weekly D808 (Fla. 4th DCA 2013)
4TH DCA
See also  Davis v. Monahan, 832 So.2d 708 (Fla.2002) (holding unjust enrichment claim alleging misappropriation of funds by family members for transactions occurring from 1990 to 1992 barred by statute of limitations as complaint not filed until 1997); Swafford v. Schweitzer, 906 So.2d 1194 (Fla. 4th DCA 2005) (holding statute of limitations limited plaintiff’s right to recover for improvements to real property to those improvements made within four years of filing of complaint); Matthews v. Matthews, 222 So.2d 282, 286 (Fla. 2d DCA 1969) (“[I]n quantum meruit [claim for services] and quantum valebant [claim for goods], the cause of action accrued when the services have been performed or the property transferred.”).

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