Is a claim for unjust enrichment a separate, stand-alone claim?

MultiRegion, United States of America

The following excerpt is from McFadden v. Deutsche Bank Nat'l Trust Co., No. 2:10-cv-03004 JAM KJN PS (E.D. Cal. 2011):

As an initial matter, there is a split of authority in regards to whether a claim for unjust enrichment is a separate, stand-alone claim or simply a remedy. See Davenport v. Litton

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