In a recent case, the Massachusetts Appeals Court decided whether marital fraud–that is, fraudulently inducing another person to marry–constitutes a valid civil cause of action.
Background:
In the case Shea v. Cameron, the parties married in 2007, after a two-year consensual romantic relationship. The wife owned her home individually. In 2010, she transferred title to the home, to be owned jointly with the husband; the husband’s name was added to the mortgage as well.
In 2011, the wife discovered that the husband was having an affair. She filed for divorce, then withdrew her complaint and filed for an annulment instead. During a deposition in the proceedings, the husband admitted that he was unable to love the wife very early in the marriage. He said he did not believe her to be his “one true love”. In 2013, the parties entered into a joint stipulation of annulment, which ended the marriage.
Unbeknownst to the husband, the day before the annulment, the wife filed a civil complaint related to the parties’ stipulated fraud. She sued him for false claims of love, emotionally harmful conduct, and improper use of the couple’s finances.
Superior Court:
In Superior Court, the judge ruled for the husband. The judge acknowledged that the husband made some misrepresentations about his love and commitment to the wife. However, he also concluded that the court could not intrude into the private and personal relationship of the parties, nor could the court provide relief. The judge granted summary judgment for the husband. Following that decision, the judge then reported the case to the Appeals Court.
Appeal:
On appeal, the Court first addressed whether the stipulation of fraud had any impact on the civil claims. While stipulations of fact are binding on the parties and respected by the courts, the Appeals Court explained, stipulations of law (such as the one regarding fraud in this case) are not binding on the courts.
The Court then discussed the substance of each of the eight claims brought by the plaintiff. Those claims included fraud, misrepresentation, battery, infliction of emotional distress, undue influence, and unjust enrichment. The Court first explained that Massachusetts law precludes claims of breach of a marriage contract; any civil tort action based on such a breach is unavailable in Massachusetts. As a result, the Court held that the wife’s claims based on fraud were precluded.
Emotional distress:
Next, the Court reviewed the wife’s claims for infliction of emotional distress. It held that an adulterous affair (even if meant to cause emotional harm) is not “extreme and outrageous” as required in order to prove a claim for emotional distress. Likewise, the husband’s failure to disclose past sexual or romantic history didn’t rise to the level of that tort claim.
Ownership of the home:
Finally, the Court considered the wife’s claims for damages for the exchange of money and her home between the parties over the course of their relationship. The wife claimed that she would not have given ownership of her home to the husband had it not been for the husband’s coercive or fraudulent conduct. The Court held, however, that the record showed insufficient evidence in this regard; it upheld the trial court’s grant of summary judgment.
Decision:
“As evidenced here, not all human actions in the context of the dissolution of a marriage have an avenue for legal recourse, no matter how much anger, sorrow, or anxiety they cause,” the Court noted. “This court respects the difficult work done by Probate and Family Court in disentangling marital relationships. The process of divorce provides an avenue for alimony and the equitable distribution of property. By voluntarily withdrawing her complaint for divorce and entering into a stipulation and judgment of annulment, [the wife] chose to forgo that process and her claims could not survive in Superior Court.”
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