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Moving company's suit against a school district for unjust enrichment barred
Wayne Moving & Storage of New Jersey, Inc. v. Sch. Dist. of Philadelphia, 09-3890, concerned a challenge to the district court's grant of plaintiff's motion for summary judgment and an award of $830,071.18 plus interest, in plaintiff's suit against a school district under a theory of unjust enrichment for unpaid moving services.
In reversing the judgment, the court remanded the matter as, plaintiff's claim of unjust enrichment is barred by Section 508 of the Pennsylvania Public School Code, which applies to "contracts of any kind," including those contracts implied by courts in unjust enrichment claims, and here, because the acts of the school district not in compliance with the provisions of Section 508 are rendered "void and unenforceable," the school district cannot be bound under an implied contract of unjust enrichment. The court also held that the school district is not equitably estopped from relying on Section 508.