United States First Circuit

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Goat Island South Condominium v. IDC Clambakes, Inc., 15-1771

In a bankruptcy appeal in a decades-long litigation over the Regatta Club, a lucrative banquet facility which was constructed on a parcel of land at a time when the validity of the development rights to that parcel was in dispute, the district court's decision, which found clear error in the bankruptcy court's characterization of the benefit conferred on debtor as merely a ground lease and in its unjust enrichment analysis, is reversed where the bankruptcy court properly decided: 1) to award no equitable relief to the Associations, where no implied-in-fact contract existed between the parties; and 2) as to unjust enrichment, there is nothing in the America opinions to suggest that their holding regarding the Regatta Club's ownership should bear on the question of whether principles of equity entitle the Associations to even more relief than the Rhode Island Supreme Court already afforded them. Thus there wa no abuse of discretion in the bankruptcy court's ultimate decision that the Associations failed to meet their burden of showing that inequity would result if debtor did not pay them for the use and occupancy of the Regatta Club during the claim period.

Appellate Information

  • Argued
  • Submitted
  • Decided
  • Published 2017/03/27




  • United States First Circuit


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