R. Klein v. Doyle Beck

After a four-day trial, a jury returned a verdict in favor of Plaintiff-Appellee R. Wayne Klein (“the Receiver”), finding Defendant-Appellant Doyle Beck (“Beck”) liable under a theory of unjust enrichment in the amount of $55,000. Beck appeals the district court’s denial of his motions under Federal Rules of Civil Procedure 50(a), 50(b), and 59(e) as well as the overruling of his objection to a jury instruction on unjust enrichment. We affirm.

As the parties conceded at oral argument, this appeal turns on one dispositive, legal issue: does Idaho’s enactment of the Uniform Fraudulent Transfer Act (the “IUFTA”) displace an equitable claim of unjust enrichment? Although Idaho courts have yet to address the issue, we agree with the district court’s conclusion that the IUFTA does not categorically displace the unjust enrichment claim in this case.

The IUFTA provides that “[ujnless displaced by the provisions of this act, the principles of law and equity ... supplement its provisions.” IDAHO CODE ANN. § 55-919 (2014). Under Idaho law, a statute cannot displace the common law absent clear implication. Mickelsen v. Broadway Ford, Inc., 153 Idaho 149 , 280 P.3d 176, 179-80 (2012).…