Adelman v. Christy
In Adelman v. Christy, 90 F. Supp. 2d 1034 (D. Ariz. 2000), the plaintiff sought to recover for research services she had provided the defendant author and publisher of a book. 90 F. Supp. 2d at 1036.
The Adelman court concluded that the plaintiff could pursue an unjust enrichment claim as an alternative theory of recovery in conjunction with her breach of contract claim, subject to only one recovery. Id. at 1045-46.
The court held that allowing the alternative theory of recovery was appropriate in case the contract was found invalid or the plaintiff was deemed the breaching party, in which case the plaintiff would not have a remedy at law to recover payment for the services she had rendered. Id. at 1045, n.10.