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Timmer v. Gray

395 N.W.2d 477 (Minn. Ct. App. 1986)

tl;dr: A good faith purchaser for value who fails to inspect the property before purchase is subject to a lien to prevent unjust enrichment.

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This is a legal case where Martin Timmer and others are appealing against William Gray and Jed Maggert. The Timmers sought possession of two farm discs they had purchased from Farmers Home Administration. The trial court granted possession to the Timmers but subject to an equitable lien in favor of Jed Maggert, who had repaired the discs. The court found that Maggert's unpaid repair bill necessitated an equitable lien to prevent unjust enrichment of the Timmers. The Court of Appeals affirmed the trial court's decision. The issue is whether the trial court erred in awarding Maggert an equitable lien based on the theory of unjust enrichment.

The trial court granted Maggert an equitable lien based on the theory of unjust enrichment, which is necessary in this case due to the failure of consideration, mistake, and moral wrongness involved. The equitable lien is enforceable against anyone who subsequently acquires the property, except for a bona fide purchaser for value without notice of the lien. The Timmers cannot be considered bona fide purchasers as they paid a nominal amount for property worth much more, which does not constitute value. Maggert's lien is not expunged by the Timmers' purchase.

The court affirms the trial court's order granting Maggert an equitable lien on the Timmers' discs since they did not inspect and pay for the discs, preventing unjust enrichment. It is unclear whether the Timmers have rescission rights on their purchase of the discs.

IRACIssue, Rule, Analysis, Conclusion

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Facts & Holding

Facts:Gray took possession of two farming discs from his neighbor,...

Holding:Maggert was entitled to an equitable lien on the disc...

Timmer v. Gray

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