What is the proper approach to the juristic reason analysis?

The proper approach to the juristic reason analysis requires that the plaintiff first show that no juristic reason from an established category exists to deny recovery. The established categories include a contract, a disposition of law, a donative intent, and other valid common law, equitable or other statutory obligations. If there is no juristic reason from an established category, then the plaintiff has made out a prima facie case under this element of the analysis. (Garland v. Consumers’ Gas Co., at para. 44.)

The defendant can rebut the prima facie case where the defendant can show that there is another reason to deny recovery. At this stage of the analysis, the court can look to all of the circumstances of the transaction in order to determine whether there is another reason to deny recovery. (Garland v. Consumers’ Gas Co., at para. 45.) As part of the defendant’s attempt to rebut, the court should have regard to the reasonable expectations of the parties and public policy considerations. (Garland v. Consumers’ Gas Co., at para. 46.) Absence of Juristic Reason