Cates v. Swain
Annotate this CaseElizabeth Swain and Mona Cates lived together from 2000 until 2006. After they severed their relationship, Swain filed an action seeking the repayment of funds she first had invested in a property in Washington State, which were then used to purchase a residence in Mississippi. The chancellor rejected Swain's claim of a constructive trust or a resulting trust. The chancellor found that Cates had been unjustly enriched by Swain's contributions and awarded Swain a judgment in that amount. The Court of Appeals affirmed the chancellor's rejection of the trust claim but reversed the decision of the chancellor, which was based on unjust enrichment. The Court of Appeals held that, because “cohabitation alone cannot form the basis of an equitable remedy between non-married cohabitants,” the remedy of unjust enrichment was outside the bounds of the chancery court's equitable powers. Upon review, the Supreme Court found that the chancellor was empowered to award relief on the basis of unjust enrichment. The Court affirmed the judgment of the Court of Appeals to the extent that it affirmed the chancellor's rejection of Swain's claim of a constructive trust or a resulting trust. The Court reversed the judgment of the Court of Appeals with regard to the unjust-enrichment award. Because the chancellor made a mathematical error in the calculation of the unjust-enrichment award, the Court vacated the chancellor's judgment in part, and remanded the case to the chancery court for entry of judgment in the correct amount.
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