In an action for money had and received, plaintiff alleged that the International Railroad Company owed plaintiff $40,000 as compensation for services rendered under an existing and valid contract of employment; that with knowledge of this fact defendant corporation, representing that it, and not plaintiff, was entitled to this sum, fraudulently conspired with International Railway Company that this sum be paid defendant instead of plaintiff, and that said amount was paid defendant, resulting in unjust enrichment under circumstances in which the law implies a promise on defendant's part to pay said sum to plaintiff. In reversing a judgment sustaining a demurrer to the complaint, the court held that the tort of inducing breach (non-payment) of the employment contract rendered defendant liable in quasi-contract. Caskie v. Philadelphia Transit Co., 321 Pa. 157, 184 A. 17 (1936).
QUASI-CONTRACT AS AN ALTERNATIVE REMEDY FOR INDUCING BREACH OF TORT,
Mich. L. Rev.
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