Recovery for Services Rendered. Garris Briggs died on October 11, 1990, leaving $782 in unpaid medical bills. Following his death, insurance checks in the amount of $676.72, payable to Briggs, were sent to his widow, Beatrice Briggs. The Briggses had

Question

been living apart for the previous five years and during that time had not had any financial connections. Under state law, a surviving spouse, upon the execution of an affidavit before the appropriate county official, was entitled to all of the estate's assets without administration, and the assets of the estate up to $5,000 were free from all debts of the decedent (the one who died). Garris Briggs's estate was worth less than $5,000, so Beatrice Briggs signed the necessary affidavit, cashed the checks, and deposited the funds. The physicians who had provided medical services for Garris Briggs sued the widow to recover the insurance proceeds. The widow claimed that because she had not lived with her husband for five years, she should not be liable for his debts. Should the physicians be allowed to recover the insurance proceeds from Beatrice Briggs? Discuss fully.

Answer 1

Recovery for services rendered
The Superior Court of New Jersey held that to allow the widow to keep the funds, which were intended to cover the husband's medical expenses, would constitute unjust enrichment. The court first expressed its view that the state legislature, when drafting the law exempting the first $5,000 of a decedent's estate from the satisfaction of the decedent's debts, did not intend insurance proceeds paid with a specific purpose in mind to be included as "assets of the estate." Because the insurance proceeds were issued as a direct result of the services provided to Griggs by the physicians, the court held that "it is only just and fair that they be used for their intended purpose; that result is mandated by good conscience and fairness." The court pointed out that the doctrine of unjust enrichment, on which quasi-contractual obligations are frequently based, "rests on the equitable principle that a person shall not be allowed to enrich himself unjustly at the expense of another." In this case, the judge concluded that it was "disingenuous for defendant to have claimed that she is not liable because the marriage was not viable, and at the same time claim to be entitled to the proceeds of the insurance because she was the widow in fact of decedent. It is certain to me that she should have used these funds for the purpose for which they were issued. Otherwise, she will have been unjustly enriched, at the expense of plaintiffs, by an interpretation of a statute that I find the legislature did not contemplate."