Reclaimant Corp. v. Deutsch
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The Supreme Court reversed the judgment of the trial court rendering summary judgment in favor of Defendants after concluding that Plaintiff's unjust enrichment claims were governed by Delaware law and were thus time-barred, holding that Connecticut law, rather than Delaware law, controlled the timeliness of Plaintiff's claims.
Plaintiff brought unjust enrichment claims against Defendants seeking recovery for alleged overpayments issued to Defendants by Plaintiff's putative predecessor in interest pursuant to a limited partnership agreement. The trial court concluded that Plaintiff's claims were governed by Delaware law and were therefore time-barred. The Supreme Court reversed, holding (1) Delaware law governed the substantive rights and liabilities of the parties arising out of the limited partnership agreement, but Connecticut law governed matters of judicial administration and procedure; and (2) because Plaintiff's unjust enrichment claims had a common-law origin, the limitation period properly was characterized as procedural, and therefore, Connecticut law governed the timeliness of Plaintiff's unjust enrichment claims.
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