“Moreover, even accepting that Ms. Lovsin’s services benefited Jack and Meryl Hodgins, this conferring of a benefit does not, by itself, constitute unjust enrichment. As Dickson J. said in Pettkus v. Becker, 1980 CanLII 22 (SCC), [1980] 2 S.C.R. 834 at p. 848: “The common law has never been willing to compensate a plaintiff on the sole basis that his actions have benefited another.”
To show that the enrichment was unjust, the provider of the benefits (here Ms. Lovsin) must reasonably expect to be compensated, and the recipients of the benefits (here Jack and Meryl Hodgins) must know or ought to have known of that reasonable expectation. In the words of Dickson J. at p. 849 of Pettkus:
[w]here one person in a relationship tantamount to spousal prejudices herself in a reasonable expectation of receiving an interest in property and the other person in the relationship freely accepts benefits conferred by the first person in circumstances where he knows or ought to have known of that reasonable expectation, it would be unjust to allow the recipient of the benefit to retain it.”