Brown v. Strum
United States District Court for the District of Connecticut
350 F. Supp. 2d 346 (D. Conn. 2004)
Relevant factsFree
Brown (plaintiff) met Strum (defendant) through online dating; Strum repeatedly claimed to be divorced and looking to remarry, and the two dated and were intimate, but Strum was actually still married. Brown sued for fraud and intentional infliction of emotional distress, and Strum moved to dismiss for failure to state a claim.
IssueFree
Whether a plaintiff may circumvent a statutory prohibition on heart-balm claims by recasting a heart-balm claim as one for fraud or intentional infliction of emotional distress.