Vertex, Inc. v. City of Waterbury

Facts

In March 1999, Vertex, Inc. (Plaintiff) offered to prepare the computer systems of the City of Waterbury (Defendant) for problems associated with the year 2000. Plaintiff accepted and work commenced that month. The parties entered a formal written contract detailing the tasks to be performed in June 1999. On July 1, 1999, Plaintiff sent Defendant a proposal to perform additional work to address problems it had identified in its first few months of working under the contract. It is disputed whether Defendant accepted the July 1999 proposal. Plaintiff performed the additional work proposed in the July 1999 proposal but Defendant refused to pay for the additional work. Plaintiff sued alleging, among other claims, unjust enrichment. A jury trial was held. Plaintiff requested a jury instruction explaining that, to prove an unjust enrichment claim, the plaintiff must show that the plaintiff provided services to the defendant, that the defendant benefitted, that the defendant unjustly failed to pay for the benefit, and that the defendant’s refusal to pay was detrimental to the plaintiff. The court rejected the proposed instruction and instead instructed the jury on implied-in-fact contracts. The jury was unable to reach a verdict and the court declared a mistrial. After the case was retried, the jury found in favor of Defendant. Plaintiff brought a motion to set aside the verdict and obtain a new trial, on grounds that the court improperly instructed the jury as to its unjust enrichment claim.