No Unjust Enrichment in Jail Contract Dispute

-Defendant Dearborn County, Indiana (“the County”), for certain architectural services connected to a project to renovate and expand the Dearborn County Jail (“the Project”). The Contract provided that RQAW would complete a Pre-Design Study, which
would evaluate how to best meet the County’s then-current and future needs. In relation to the Pre-Design Study, the parties agreed that the County would pay RQAW the sum of $90,000. The Contract further indicated that any further work and the cost for such work would be determined at a later time.  RQAW completed the Pre-Design Study and the County paid RQAW the
agreed-upon $90,000.
After completion of the Pre-Design Study, the County decided to seek proposals from a number of architectural firms in connection to the design, bidding, and construction phases of the Project. Although RQAW submitted a proposal for this work, the County ultimately decided to move forward on the Project with a different architectural firm.

RQAW subsequently filed suit, alleging that the County had breached its contract with RQAW. RQAW also alleged that it was entitled to recover damages under the equitable theory of unjust enrichment. As to RQAW’s breach of contract claim, the parties filed competing motions for summary judgment. As to RQAW’s equitable claim, the County filed a motion for judgment on the pleadings. Following a hearing, the trial court granted the County’s motion for summary judgment, denied RQAW’s motion for summary judgment, and granted the County’s motion for judgment on the pleadings.

RQAW challenges these rulings on appeal. We affirm.
To read the full opinion, click here.
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