Unjust Enrichment Claim Barred in Part by Four Year Statute of Limitations

A health care worker’s claim for services to the decedent was properly dismissed by summary judgment when the plaintiff admitted that there was no express contract for services and the history of payments by the decedent and the decedent’s agent was insufficient to establish a contract implied in fact. However, a claim for unjust enrichment was not properly dismissed by summary judgment when the plaintiff’s evidence, if believed, was sufficient to show that she provided services to the decedent within the four year statute of limitations, that the decedent accepted those services and had reason to know that the plaintiff expected to be paid for those services, and that the decedent did not pay the plaintiff. Barbara Ross v. Estate of Helen F. Roberts, 393 MDA 2023 (Pa. Super. 9/15/2023) (non-precedential).

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