PAUL v. NOTO NEXUS LLC (2026)

MEMORANDUM DECISION

Case Summary

[1] Joel Samuel Paul appeals the small-claims court's judgment for The Noto Nexus, LLC, on his claim of unjust enrichment. We affirm.

Facts and Procedural History

[2] Noto Nexus is a recruiting firm owned by Ellis Noto. In August 2024, Noto Nexus hired Paul as Director of Legal Recruiting. His role was to identify candidates to place at law firms nationwide, and he received a salary plus commissions for each placement. That October, Paul signed up for a “LinkedIn Recruiter account” to search for candidates to place at law firms. Appellant's App. Vol. 2 p. 7. The account cost $7,500 for one year, which Paul paid himself in monthly installments of $625.

[3] Paul resigned from Noto Nexus in March 2025. The following month, Paul, pro se, brought a small-claims action against Noto Nexus for unpaid wages. Noto Nexus, pro se, moved to dismiss the claim, and the small-claims court granted dismissal but allowed Paul to amend his notice of claim. His amended notice of claim alleged unjust enrichment on the ground that he “rendered a measurable benefit to [Noto Nexus] by entering into the contract with LinkedIn for a LinkedIn Recruiter account,” and Noto Nexus failed to pay him for the account. Id. at 8. Paul claimed that he “expected payment from” Noto Nexus because Ellis Noto “verbally promised” at Paul's resignation meeting that Noto Nexus “would cover the cost” of the LinkedIn account. Id. Noto Nexus moved to dismiss the amended notice of claim under Indiana Trial Rule 12(B)(6) for failure to state a claim upon which relief can be granted.

[4] The small-claims court held a hearing on Noto Nexus's motion in December. Noto Nexus, then represented by counsel, argued that it retained no benefit from Paul's LinkedIn Recruiter account because Paul opened the account on his own, and it wasn't transferred to Noto Nexus after Paul resigned. Paul acknowledged that the account was no longer active because the subscription was for only one year. Additionally, upon questioning by the court, Paul admitted that the alleged promise by Noto to reimburse the $7,500 was a verbal agreement and that he didn't have any evidence of such agreement beyond his own testimony. Noto testified that he didn't recall telling Paul at his resignation meeting that he'd reimburse the $7,500. Instead, Noto recalled that “Paul had requested an increase in his ․ salary in exchange for entering into the agreement with LinkedIn Recruiter,” which Noto Nexus paid. Tr. p. 13. Noto added that Noto Nexus “ha[s its] own subscription already paid for a LinkedIn Sales Navigator, so [it] wouldn't need a double subscription.” Id. at 15.

[5] After the hearing, the small-claims court entered judgment for Noto Nexus.

[6] Paul, still pro se, now appeals.

Discussion and Decision

[7] Paul contends that the small-claims court erred in entering judgment for Noto Nexus. “Our standard of review in small claims cases is particularly deferential in order to preserve the speedy and informal process for small claims.” Heartland Crossing Found., Inc. v. Dotlich, 976 N.E.2d 760, 762 (Ind. Ct. App. 2012).

[8] As Paul notes, the small-claims court's written judgment indicates that it granted Noto Nexus's motion to dismiss. Paul argues that the court should have denied Noto Nexus's motion to dismiss and instead “the matter should have been scheduled for bench trial.” Appellant's Br. p. 7. But even though the court called the December proceeding a hearing on Noto Nexus's motion to dismiss, it was effectively a bench trial. “[I]n small claims actions, ․ trials are ‘informal, with the sole objective of dispensing speedy justice between the parties according to the rules of substantive law.’ ” Lae v. Householder, 789 N.E.2d 481, 483 (Ind. 2003) (quoting Ind. Small Claims Rule 8(A)). Indeed, the purpose of the Small Claims Rules is to assure “speedy decisions without application of procedural rules.” McClure v. Cooper, 893 N.E.2d 337, 340 (Ind. Ct. App. 2008). Small Claims Rule 8(B) provides that all testimony shall be given under oath or affirmation, and witnesses may be called. That is what happened here. The court administered an oath to Paul at the start of the proceeding. The parties each gave an opening statement. Paul then had the opportunity to testify when the court questioned him. And the parties conducted direct and cross-examination of Noto, who was also under oath, before presenting closing arguments. All the elements of a bench trial were present here. Given the informality of small-claims actions, we conclude that the December proceeding—regardless of the label the court gave it—was a trial.

[9] Accordingly, we will consider the court's ruling as an adjudication on the merits rather than a mere 12(B)(6) dismissal. We thus turn to the merits of Paul's claim. “To prevail on a claim of unjust enrichment, a plaintiff must establish that a measurable benefit has been conferred on the defendant under such circumstances that the defendant's retention of the benefit without payment would be unjust.” Kohl's Ind., L.P. v. Owens, 979 N.E.2d 159, 167 (Ind. Ct. App. 2012). Paul cannot do so here. He hasn't shown that his purchase of the LinkedIn Recruiter account conferred a measurable benefit on Noto Nexus or that Noto Nexus retained any benefit—Paul opened the account in his own name, the account wasn't transferred to Noto Nexus after he resigned, Noto Nexus already had its own LinkedIn Sales Navigator subscription, and the Recruiter account was no longer active at the time of trial because the subscription was for only one year. And even if Noto Nexus had retained a benefit, Paul failed to show that he wasn't paid for it. Noto testified that, at Paul's request, Noto Nexus increased his salary in exchange for Paul personally paying for the LinkedIn Recruiter account, and Paul didn't present any evidence disputing this.

[10] Because Paul failed to make any of the requisite showings to support his unjust-enrichment claim, we affirm the judgment of the small-claims court.

[11] Affirmed.

Vaidik, Judge.

Altice, J., and Foley, J., concur.