Waage v. Borer

In Watts v. Watts, 137 Wis. 2d 506, 532-33, 405 N.W.2d 303, 314 (1987), our supreme court recognized actions in unjust enrichment by unmarried cohabitants following the termination of their relationships, for recovery of their share of wealth, accumulated through their joint efforts and retained by one of the parties in an unreasonable amount.

In this case, Dale E. Bower and Donald Waage were nonmarital cohabitants for about eight years. Bower claimed money for her housekeeping efforts during that period of time, after Waage reneged on an alleged promise to marry her. A jury found that Waage…