Law School Case Brief
Marvin v. Marvin - 122 Cal. App. 3d 871, 176 Cal. Rptr. 555 (1981)
A rehabilitation award, being nonconsensual in nature, must be supported by some recognized underlying obligation in law or in equity. A court of equity admittedly has broad powers, but it may not create totally new substantive rights under the guise of doing equity.
After an unmarried couple, Lee Marvin and Michelle Marvin, ended their cohabitation at Lee's insistence, Michelle filed an action against him seeking support and maintenance. Lee Marvin was a reknown actor. In a trial without a jury, the trial court found that Lee had no obligation to pay Michelle a reasonable sum for maintenance, that Michelle suffered no damage resulting from her relationship with Lee, including its termination, and Lee did not become monetarily liable to plaintiff at all. However, the trial court found it was doubtful that Michelle could return to the career she had enjoyed before the relationship of the parties commenced and that she was in need of rehabilitation. Accordingly, the trial court entered a judgment ordering defendant to pay Michelle the sum of $104,000 to be used by her primarily for her economic rehabilitation.
Did the trial court err in ordering economic rehabilitation award in favor of Michelle?
The appellate court reversed the award because the pleadings did not request an economic rehabilitation award and there was no basis in law for an economic rehabilitation award. The court accepted the trial court's findings that Lee had no obligation to support Michelle, Michelle did not suffer any damage as a result of the relationship with Lee, and Michelle benefitted socially and economically from the relationship. Therefore, Lee was not unjustly enriched at the expense of Michelle and Lee did not perform any wrongful act against Michelle, and as a result, there was no basis in the law for Michelle to receive an economic rehabilitation award.
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