Justia Non-Profit Corporations Opinion Summaries

A man who founded a nonprofit community radio station in Wyoming contributed substantial sums of money to the station over several years. He claimed these were loans intended to support the station’s operations and expected repayment. Although he discussed loan terms with the station’s board and referenced a loan at a board meeting, no written agreement was ever executed, and he did not follow through on drafting a loan contract. Despite the lack of formal documentation, the station’s tax filings, prepared with his assistance, listed the contributions as loans, but other board members were not aware of or had not approved these filings until after he withdrew a significant amount as “repayment” and subsequently left the station.The District Court of Teton County reviewed the claims after the parties filed cross-motions for summary judgment. The plaintiff alleged breach of implied contract and unjust enrichment, asserting that the station’s tax filings and board members’ awareness supported his claims. The district court found no evidence of a written or oral agreement approved by the board, determined that the statute of frauds barred the implied contract claim, and granted summary judgment to the defendant. The court also found the unjust enrichment claim was barred by the statute of frauds.On appeal, the Supreme Court of Wyoming reviewed the district court’s judgment de novo. The Supreme Court affirmed the district court’s ruling that the breach of implied contract claim was barred by the statute of frauds, as no definite or certain terms existed to remove the agreement from the statute’s requirements. However, the Supreme Court clarified that Wyoming law does not bar unjust enrichment claims by the statute of frauds. Nevertheless, it held that the plaintiff failed to show the station was reasonably notified that repayment was expected, as required for unjust enrichment. The Supreme Court affirmed the district court’s grant of summary judgment for the defendant. View "Tallichet v. Jackson Hole Community Radio, Inc." on Justia Law