Orlando v. Liburd

Summary

The court held that the plaintiff's unjust enrichment claim against his automobile insurer was ripe even though he had not yet obtained a judgment against the tortfeasor or exhausted collection efforts. The alleged injury—the insurer's premature subrogation and resulting invasion of the plaintiff's priority to limited liability coverage—had already occurred, while only the precise amount of damages remained uncertain. The court also held that the plaintiff had standing because he alleged a specific, personal, and legally protected interest that the insurer's subrogation recovery may have adversely affected.