After You Break Up, Dont Expect To Get Paid For Those Home Repairs You Did For Your Girlfriend While You Were Dating

by:  Peter J. Gallagher (@pjsgallagher) (LinkedIn)

Tools (pd)Nothing says romance like asking your girlfriend to sign a contract before you agree to help her fix up her house. Nonetheless, this is essentially the take-home message from the Appellate Division's decidedly unromantic decision in Sukenik v. Dizik.

In Sukenik, plaintiff and defendant dated for approximately 18 months. "Beginning in January 2014, they spent every weekend and holiday together, with plaintiff frequently staying overnight in defendant's home." Eventually, plaintiff moved into defendant's home.

Plaintiff claimed that while he and defendant were dating, he "spent substantial sums not only on mutual expenses such as vacations and dinners, but also on needed improvements to defendant's home and property because the home was in poor condition." He testified that he spent more than $8,000 on materials. He also "contributed his labor, which he valued at $3,000." Unfortunately for plaintiff, "the relationship ended shortly after he underwent kidney surgery on June 18, 2015, when defendant demanded he move out of her home." Two weeks later, plaintiff sued, seeking to recoup the costs of the materials and labor he contributed to the repairs on defendant's home. Defendant denied liability, arguing that the improvements plaintiff made to her home were unconditional gifts.

Plaintiff was the only witness to testify at trial. After his testimony, defendant moved for involuntary dismissal. The trial court granted the motion, and plaintiff appealed.

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Another Pleasant Valley Sunday In Suburbia

by:  Peter J. Gallagher

Outside of a handful of major cities, New Jersey is essentially "suburbia," so it was with great interest that I read a recent article in USA Today, "Suburban Growth Focused On Inner and Outer Communities," which was discussed on the Land Use Prof Blog, in a post entitled "Types of Suburbia . . . ."  The article and post discuss the development of different types of suburbs and the population growth that they have seen over the past 10-15 years.  For instance, the "inner suburbs" that developed in the 1920s and 1930s along streetcar lines have seen double-digit population growth over this period, primarily because they are close to the city and are accessible via public transportation.    These areas have older buildings, so there is less reluctance on the part of the residents to rebuild and renovate.  In contrast, the "mature suburbs," which were built in the 1970s and 1980s, are slightly beyond the reach of public transportation, and are not yet old enough to justify large-scale rebuilding and renovation, have seen the slowest growth in the last 10-15 years.  (I think I live in a "mature suburb," but there was little reluctance on our part to renovate some of the design features and home improvement decisions made by the prior owners in the 1970's and 1980's.)  Regardless, whether you live in an "inner suburb," a "mature suburb," or an "emerging suburb," the article and post are interesting and worth a few minutes of your time.