Marvin v. Marvin (III)
California Court of Appeal
122 Cal. App. 3d 871 (1981)
Michelle Marvin (plaintiff) and Lee Marvin (defendant) lived together unmarried from 1964 until Lee ended the relationship in 1970. Michelle claimed the couple had both an express agreement (that she'd give up her dancing career to be Lee's companion and homemaker in exchange for lifetime financial support) and an implied agreement to the same effect, and that she gave up a career she could not easily reenter. On remand from an earlier appeal allowing her express- and implied-contract claims to proceed, Lee denied both agreements. The trial court found Michelle had actually come out financially ahead from the relationship (receiving more from Lee than she would have earned on her own) yet still awarded her $104,000 for "economic rehabilitation" since she could no longer work as a dancer; Lee appealed.
Whether (1) an award of support intended to make whole a party who acted in reliance upon her own understanding of the terms of a cohabitating relationship is an appropriate equitable remedy, and (2) nonmarital cohabitation confers any rights, in equity or law, for economic remedies upon the termination of the relationship.