"[T]he district court did not abuse its discretion when it found that [the Life Insurance Company of North America (LINA)] held [former president Daniel] Rochow's wrongfully withheld money in its general account where it could be used for any business purpose, as opposed to a segregated investment account.... Second, the district court did not abuse its discretion by selecting [return on equity (ROE)] as the metric for calculating a reasonable approximation of LINA's profits. While there is a dearth of case law expressly applying the ROE metric to determine unjust enrichment, selecting ROE as a basis for calculating LINA's profits does not violate any clearly established principle of law or equity." [Rochow v. LINA, No. 12-2074 (6th Cir. Dec. 6, 2013)]  MORE >>