## Facts

- Margaret Barrett owned Riverdale Plantation in St. Francis County, Arkansas; after her 1979 death, the plantation was devised to Mary A. Kistler, and R. A. Ashley, Jr. administered the estate.
- For over twenty years, William K. Stoddard annually leased 208 acres on an oral basis; after Barrett’s death, the arrangement was put into written yearly leases through December 31, 1981.
- In fall 1981, consistent with prior practice, Stoddard planted winter wheat expecting to harvest in spring 1982.
- Stoddard planted without knowledge that the plantation would be sold and in reliance on the longstanding course of dealing that his lease would be renewed and he would be allowed to harvest.
- In March 1982, Shannon Brothers Enterprises, Inc. purchased the plantation knowing the wheat was already planted; the wheat’s value did not increase the purchase price.
- Shannon declined to renew Stoddard’s lease after it expired on December 31, 1981, later harvested and sold the wheat, and refused the estate’s demand for reimbursement of planting costs (not the crop’s value).

## Issues

1. Whether unjust enrichment permits restitution for a former tenant’s planting costs when the purchaser harvests the crop, even though the tenant had no continuing leasehold or legal claim to the crop at harvest.

## Decision

- The Arkansas Court of Appeals affirmed the chancery court’s decree awarding $5,711.93 in restitution.
- The court accepted findings that Stoddard planted in good faith and in reasonable reliance on a long course of annual renewals.
- The court held that although the estate had no legal or equitable claim to the crop itself, the purchaser would be unjustly enriched by retaining the benefit of Stoddard’s labor and expenditures without reimbursement.
- Applying de novo review with deference to factual findings unless clearly erroneous, the court concluded the chancellor’s unjust-enrichment finding was not clearly erroneous.

## Legal Principles

- Unjust enrichment is an equitable doctrine preventing one party from benefiting at another’s expense due to an innocent mistake or unintentional error.
- Restitution may be awarded even when the claimant lacks legal or equitable title to the property that generated the benefit, if the defendant knowingly accepts and retains the benefit under circumstances making nonpayment unjust.
- Where appropriate to avoid a windfall, restitution may be measured by the claimant’s expenditures (e.g., planting costs) rather than the full value of the benefit received.

## Conclusion

The court upheld a restitution award requiring reimbursement of a tenant’s wheat-planting costs because the purchaser knowingly harvested a crop planted in good-faith reliance on past renewals, and retaining the resulting benefit without payment would be unjust enrichment.


Kistler v. Stoddard, 15 Ark. App. 8, 688 S.W.2d 746 (Ark. Ct. App. 1985)