Son Not Entitled to Management Fee for Handling Father’s Estate

In 2004, a farmer disappeared and was never heard from again.  His son moved back to the farm and began operating the farm, including paying the expenses and personally receiving the farm income.  In 2009, some of the surviving children requested a declaration of their father’s death and asked for the appointment of an administrator. The court declared the father dead and appointed one of the farmer’s daughters as administrator.  Estate proceedings were later begun.  During estate administration, the son filed a claim for farm management fees in the amount of $316,000.  The administrator denied his claim and the trial court held that the son was only entitled to reimbursement for any amounts paid on the principal of the farm mortgage during his occupancy. 

The son appealed, claiming that the other beneficiaries were unjustly enriched and that he should have been compensated like a farm manager, because he stepped in and performed the requisite tasks to keep the farm operational. To recover damages for claims of unjust enrichment and quantum meruit (principles of contracting), a plaintiff must show that the services he provided were beneficial to others and not personally, and the services rendered were a detrimental to the plaintiff.  While the issues of quantum meruit and unjust enrichment were not property before the court, the appellate court said the son would not have been able to prevail on those contract-based claims in any event.  According to the  court, the son had already been compensated by the income he took from the farm for the services he rendered (he received all of the income, including government payments, cash rent, crop proceeds, proceeds of cattle sales and lived in the home rent-free.). Thus, the court determined that the son had already been fully compensation.  In re Estate of Douglas, No. 1-295/10-0796, 2011 Iowa App. LEXIS 348 (Iowa Ct. App., May 25, 2011).