Baker v. Rincon

CourtColorado Court of Appeals
DecidedNovember 14, 2024
Docket24CA0323
StatusUnknown

This text of Baker v. Rincon (Baker v. Rincon) is published on Counsel Stack Legal Research, covering Colorado Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Baker v. Rincon, (Colo. Ct. App. 2024).

Opinion

24CA0323 Baker v Rincon 11-14-2024

COLORADO COURT OF APPEALS

Court of Appeals No. 24CA0323 El Paso County District Court No. 23CV30775 Honorable Eric Bentley, Judge

Rachel Elizabeth Baker,

Plaintiff-Appellee,

v.

Eduardo Ivan Rincon,

Defendant-Appellant.

JUDGMENT AFFIRMED

Division III Opinion by JUDGE GOMEZ Dunn and Navarro, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced November 14, 2024

Modern Family Law, Craig R. Valentine, Colorado Springs, Colorado, for Plaintiff-Appellee

Janko Family Law, Sabra Janko, Colorado Springs, Colorado, for Defendant- Appellant ¶1 Defendant, Eduardo Ivan Rincon, appeals the judgment

entered in favor of plaintiff, Rachel Elizabeth Baker, following a trial

to the court. Rincon contends that the trial court reversibly erred

by (1) determining that he was unjustly enriched by Baker’s

conveyance of a one-half undivided interest in her house to him and

(2) not considering the rent payments Baker received from others

who lived in the house in its calculation of Rincon’s equitable share

of the house. We disagree and affirm.

I. Background

¶2 Baker and Rincon were in a romantic relationship for about

five years, from sometime in 2018 to March of 2023. In early 2021,

Baker purchased a house and took out a mortgage on it. Baker was

the sole owner of the house and the sole person responsible for the

mortgage payments.

¶3 Baker and Rincon lived in the house together, along with

several other friends and family members, all of whom paid rent to

Baker. Rincon initially paid $500 per month in rent, but it wasn’t

revealed how much the other people paid.

1 ¶4 The house needed substantial work, so Baker made significant

improvements to it with the help of friends and family. Rincon also

helped with some of the improvements.

¶5 In April 2022, Baker executed a quitclaim deed conveying a

one-half undivided interest in the house to Rincon as joint tenants.

Baker recorded the deed. Baker later added Rincon to the title in

response to, as the trial court described it, “[Rincon’s] repeated

demands that she do so or he would leave the relationship.” Baker

also recorded this transaction. Afterwards, Rincon began paying

$750 per month in rent, but he didn’t take on any other obligations

relating to the house.

¶6 In March 2023, the couple broke up, and Rincon moved out of

the house and stopped paying rent.

¶7 Baker then brought this action to quiet title on the house

based on the transfer to Rincon having been a gift conditioned on a

marriage that never took place. She also brought claims in the

alternative to partition the house and for unjust enrichment.

Rincon counterclaimed for breach of a settlement agreement the

parties had allegedly entered into relating to the house.

2 ¶8 Following a trial to the court, the court orally ruled from the

bench. The court rejected Baker’s claim to quiet title, rejected

Rincon’s counterclaim, and reserved a ruling on Baker’s partition

and unjust enrichment claims.

¶9 In a written order, the trial court resolved the two remaining

claims. The court first addressed the partition claim by calculating

Rincon’s and Baker’s equitable shares for partition of the house;

based on the court’s calculations, Rincon’s share was $42,456.

Then, turning to the unjust enrichment claim, the court found that

Rincon was unjustly enriched because he had coerced Baker into

executing the deed and adding him to the title in order to keep their

relationship going. The court concluded that “[t]he appropriate

remedy . . . is for Rincon to quitclaim his interest in the [p]roperty

back to Baker and to receive, in turn, an amount representing his

contribution to the [p]roperty after he was added to the title.” The

court determined that Rincon was entitled to $4,000, calculated by

adding $2,000 in additional rent he had paid over the eight-month

period between when he was added to the title and when he moved

out (the additional $250 he paid each month over the $500 he’d

3 previously paid each month) and $2,000 for the work he put into

improvements in the house.

¶ 10 Accordingly, the court entered judgment directing Baker to

pay $4,000 into the court registry and directing Rincon to execute a

quitclaim deed to the property and deliver it to the court registry.

II. Unjust Enrichment

¶ 11 Rincon first contends that the trial court abused its discretion

by determining that he was unjustly enriched. Specifically, he

argues that the court erroneously found Baker’s conveyance of an

interest in the house was the result of coercion.1 We aren’t

persuaded.

A. Standard of Review and Applicable Law

¶ 12 Unjust enrichment is “a judicially-created remedy designed to

undo the benefit to one party that comes at the unfair detriment of

another.” Lewis v. Lewis, 189 P.3d 1134, 1141 (Colo. 2008).

Unjust enrichment claims require the trial court to “engage in fact-

based inquiries and make ‘extensive factual findings.’” Indian

1 While Rincon frames his argument as a challenge to any findings

of coercion, duress, or undue influence, we perceive his argument to be more cognizable as a challenge to the trial court’s determination on the unjust enrichment claim.

4 Mountain Corp. v. Indian Mountain Metro. Dist., 2016 COA 118M,

¶ 26 (quoting Lewis, 189 P.3d at 1140-41).

¶ 13 Because the power to craft equitable remedies lies within a

trial court’s discretion, we review the court’s factual findings and its

determination that a party was unjustly enriched for an abuse of

discretion. Id. A court abuses its discretion when its decision is

manifestly arbitrary, unreasonable, or unfair or is based on a

misapprehension or misapplication of the law. Far Horizons Farm,

LLC v. Flying Dutchman Condo. Ass’n, 2023 COA 99, ¶ 17.

However, we review de novo whether the trial court applied the

proper legal test for determining the existence of unjust enrichment.

Redd Iron, Inc. v. Int’l Sales & Servs. Corp., 200 P.3d 1133, 1136

(Colo. App. 2008).

¶ 14 To prevail on a claim for unjust enrichment, the plaintiff must

prove that “(1) the defendant received a benefit (2) at the plaintiff’s

expense (3) under circumstances that would make it unjust for the

defendant to retain the benefit without commensurate

compensation.” Gravina Siding & Windows Co. v. Gravina, 2022

COA 50, ¶ 34 (quoting Pulte Home Corp., Inc. v. Countryside Cmty.

Ass’n, 2016 CO 64, ¶ 63). Where a claim involves a “failed gift or

5 failed contract between close family members or confidants” who

share a “mutual purpose,” the third element doesn’t require

malfeasance. Lewis, 189 P.3d at 1142. Instead, that element may

be satisfied “when one party benefits from an action that is a

significant deviation from that mutual purpose.” Id. at 1143.

B. Application

¶ 15 In assessing Baker’s unjust enrichment claim, the trial court

noted that the first two elements were satisfied because “Rincon

unquestionably received a substantial benefit at Baker’s expense

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Baker v. Rincon, Counsel Stack Legal Research, https://law.counselstack.com/opinion/baker-v-rincon-coloctapp-2024.