Rent-A-Center East, Inc. v. Leonard, No. 14-3190 (8th Cir. 2016)
Annotate this CaseWEB2B filed for bankruptcy and turned over its balances to the Chapter 7 trustee. RAC filed suit claiming the balances of an express trust, resulting trust, or constructive trust. WEB2B provided automated clearinghouse and electronic-check conversion services to RAC. The bankruptcy court dismissed RAC's claims and granted summary judgment to the trustee. The court affirmed the district court's affirmance of the bankruptcy court's decision, concluding that the parties' processing agreement had no requirement to segregate RAC funds, nor a definite, unequivocal, explicit declaration of trust. Therefore, there was no express trust in this case. The district court did not err in concluding that the undisputed facts here do not show with reasonable certainty or beyond a reasonable doubt that a resulting trust exists. Finally, the district court properly concluded that RAC had identified no clear and convincing evidence of conversion sufficient to justify imposing a constructive trust on the remaining funds.
Court Description: Benton, Author, with Smith and Bye, Circuit Judges] Civil case - Bankruptcy. Where debtor provided automated clearinghouse and electronic-check conversion services to Rent-a-Center, the parties' processing agreement did not create an express trust; nor did the facts of the case establish a resulting trust or a post-petition constructive trust in the funds transferred to the trustee.
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