## Facts

- The United Effort Plan Trust (UEP) held legal title to land in Hildale, Utah, and Colorado City, Arizona, for the benefit of adherents to a religious community known as “The Work.”
- Community members were invited to build homes and other improvements on UEP land and were told they could live there indefinitely if they followed community rules; they could not sell or mortgage the land.
- Twenty-one residents (the claimants) constructed and occupied residences and made other improvements that increased the value of UEP land.
- The claimants relied on longstanding assurances of continued residence; before 1986, UEP had not treated them as tenants at will.
- After Rulon Jeffs assumed control, the UEP in 1986 declared all residents on UEP land to be tenants at will.
- In 1987, the claimants sued to determine their rights and asserted statutory, contract, tort, and equitable claims, plus trust-based claims (fiduciary duty, accounting, distribution).
- The trial court bifurcated proceedings, resolved the “property-rights” claims first, granted relief on unjust enrichment, and imposed a constructive trust giving claimants lifetime occupancy or compensation for improvements.
- The trial court also ruled the UEP was a charitable trust and, on that basis, denied the trust-based claims.

## Issues

1. Whether the UEP was unjustly enriched by claimants’ improvements and whether a constructive trust providing lifetime occupancy or compensation was a proper remedy.
2. Whether granting claimants equitable property-related relief impermissibly burdened other UEP members’ free exercise rights under the Utah and U.S. Constitutions.
3. Whether the UEP should be classified as a charitable trust or a private trust, affecting enforcement and available trust-based remedies.
4. Whether the trial court correctly interpreted the Utah Occupying Claimants Act and, if not, what standard should apply on remand.

## Decision

- Affirmed the unjust enrichment ruling and the constructive trust remedy providing lifetime occupancy or compensation for improvements.
- Rejected the UEP’s constitutional free-exercise challenge to the equitable relief.
- Reversed the determination that the UEP is a charitable trust.
- Reversed the trial court’s interpretation of the Utah Occupying Claimants Act and remanded for further proceedings.

## Legal Principles

- Unjust enrichment may be found when a landowner retains the benefit of improvements made by occupants in reasonable reliance on representations of continued occupancy, even if the occupants knew legal title was held by another.
- A constructive trust may be imposed as an equitable remedy to prevent the owner from retaining the value of improvements without restitution, including by securing occupancy for life or awarding compensation.
- Courts may apply neutral principles of property and equity to disputes involving religiously affiliated entities without violating free exercise, so long as adjudication does not depend on resolving doctrinal questions.
- A trust serving a limited, identifiable religious community with specific beneficiaries is generally not a charitable trust; classification affects who may enforce the trust and pursue fiduciary-duty and related remedies.
- The Utah Occupying Claimants Act protects good-faith occupants who improve land under a mistaken or uncertain understanding of rights; erroneous narrowing constructions require remand for application of the correct statutory standard.

## Conclusion

The Utah Supreme Court upheld equitable relief protecting long-term residents who improved UEP land in reliance on assurances of continued residence, held that enforcing unjust enrichment and constructive trust remedies did not violate free exercise, ruled the UEP was not a charitable trust, and remanded for proper application of the Utah Occupying Claimants Act and further proceedings on trust-related issues.


Jeffs v. Stubbs, 970 P.2d 1234 (Utah 1998)