Richards v. Brown
Annotate this CaseSteve Richards sued his former domestic partner, Diana Brown, seeking to have the relationship declared to be an unsolemnized marriage. The trial court granted partial summary judgment in favor of Brown, holding that Richards' petition was untimely. The remaining equitable claims went to trial, and ultimately, the trial court found that Brown had been unjustly enriched by Richards' contributions to home improvement and awarded Richards a money judgment. After Brown paid the judgment, Richards appealed the court's dismissal of his unsolemnized marriage claim. The court of appeals (1) held that Richards did not waive his right to appeal, and (2) reversed the trial court's grant of partial summary judgment against Richards on his unsolemnized marriage claim. The Supreme Court affirmed, holding (1) Richards did not waive his right to appeal even though he accepted payment on the unjust enrichment judgment, as a claim of unjust enrichment is separate and district from a claim of unsolemnized marriage; and (2) the court of appeals correctly interpreted the Utah Code Ann. 30-1-4.5 in determining that an end to cohabitation does not necessarily terminate a relationship.
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