Maidhoff v. Commissioner of Social Security

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE Plaintiff, Case No. C23-1691-MLP v. ORDER Defendant.

At the close of Plaintiff’s case, Defendant moved for judgment as a matter of law on Plaintiff’s unjust enrichment claim. See Fed. R. Civ. P. 54(a). In Washington, a plaintiff who is a party to a valid express contract is bound by the provisions of that contract and may not bring a claim for unjust enrichment for issues arising under the contract’s subject matter. See Chandler v. Wash. Toll Bridge Auth., 17 Wash.2d 591, 604 (1943); see also Hurlbut v. Crines, 14 Wash. App. 2d 660, 672-73 (2020). Defendant contends that all work performed was under a contractual agreement, and Plaintiff did not perform any work outside of this contract. Plaintiff acknowledges that an unjust enrichment claim is not applicable when damages arise solely from a contractual breach and admits that all damages sought are based on contractual invoices. Consequently, the Court GRANTS Defendant’s motion and DISMISSES Plaintiff’s unjust enrichment claim with prejudice. Dated this 15th day of May, 2025. A United States Magistrate Judge