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Case Citations [i] (Spring 2026)

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                            THE AMERICAN


                              LAW INSTITUTE



                                     Spring 2026 Citations



  RESTITUTION AND UNJUST ENRICHMENT 3D



Generally

N.D.Cal.2024. Cit. generally in case quot. in ftn. In multi-district litigation, thirty-four states sued
social-media company on behalf of children and adolescents, alleging that company violated states'
consumer protection laws by designing its online platforms to foster compulsive use by minors, which
resulted in a variety of harms to children, local governments, and the public health. This court denied in
part company's motion to dismiss or limit the scope of states' claims for restitution under states'
consumer-protection laws. The court explained that restitution was a term of art that varied among the
states, and that Kentucky embraced a broader approach to restitution that encompassed unjust
enrichment and disgorgement, and a willingness to adopt equitable measures where appropriate that
were consistent with the principles set forth in the Restatement Third of Restitution and Unjust
Enrichment. In re Social Media Adolescent Addiction/Personal Injury Products Liability Litigation, 753
F.Supp.3d 849, 915.

Nev.2025. Cit. generally in sup. Providers of emergency medical services sued insurers and third-party
health-insurance administrators that did not have contracts with providers, alleging that defendants were
unjustly enriched by failing to adequately compensate plaintiffs for services that providers were required
to render to defendants' members under the Emergency Medical Treatment and Labor Act. The trial
court entered judgment on a jury verdict for plaintiffs. This court affirmed in part, holding, as a matter of
first impression, that a provider that was required to provide emergency care to an insured patient had a
claim for unjust enrichment against the patient's insurer if the insurer failed to reimburse the provider
for the reasonable value of the services provided and the provider did not bill the patient for the amount
not paid by the insurer. The court looked to and found support in the Restatement Third of Restitution
and Unjust Enrichment in determining that unjust-enrichment claims were appropriate under such
circumstances. UnitedHealthCare Insurance Company v. Fremont Emergency Services (Mandavia),
Ltd., 570 P.3d 107, 120.



                                  PART  I. INTRODUCTION


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