Chalmers v. Cayne

Background

Caitlin Chalmers sued Brian Cayne after their romantic relationship ended. The complaint alleged that, during the relationship, Cayne promised to support Chalmers indefinitely, buy a home they would jointly own, share ownership and profits from future investments, and allow her to use funds as needed. Chalmers alleged that she sold her home in Canada, gave up her California apartment, left her job, disposed of many belongings, and moved in with Cayne. She also alleged that they became engaged and that Cayne later ended the relationship.

Chalmers asserted claims for breach of oral contracts for property and support, breach of implied contract, dissolution of partnership and community assets, breach of fiduciary duty, fraud, promissory estoppel, negligent misrepresentation, intentional infliction of emotional distress, conversion, and imposition of a constructive trust. Cayne removed the case from California Superior Court based on diversity jurisdiction, answered the complaint, and moved for judgment on the pleadings under Federal Rule of Civil Procedure 12(c).

Court’s Analysis

The court explained that a Rule 12(c) motion uses the same standard as a motion to dismiss for failure to state a claim. The court therefore accepted the complaint’s alleged facts for purposes of the motion and considered whether those facts stated legally sufficient claims.

The court held that California Civil Code sections 43.4 and 43.5 barred the claims for breach of oral contract, breach of implied contract, promissory estoppel, fraud, and negligent misrepresentation. Section 43.5 bars claims for breach of a promise to marry, and the court concluded that Chalmers’s alleged agreement was tied to Cayne’s promise to marry and to financial commitments traditionally associated with marriage. Section 43.4 bars damages claims based on a fraudulent promise to marry or to live as a married couple. The court also concluded that, even if the contract claims were not barred, Chalmers had not plausibly alleged a sufficiently stable and significant relationship for recovery under the California rule recognized in Marvin v. Marvin.

The court dismissed the partnership claim because Chalmers did not allege that she had a right to participate in managing or controlling the alleged partnership assets. It dismissed the fiduciary-duty claim because she did not plausibly allege that Cayne owed her a fiduciary duty or that a partnership existed from which such a duty could arise.

The court did not decide whether the alleged conduct was sufficiently extreme and outrageous for an intentional-infliction-of-emotional-distress claim because reasonable people could disagree on that issue. It dismissed the claim because Chalmers did not allege facts supporting severe emotional distress or Cayne’s intent to cause, or reckless disregard for the possibility of causing, such distress. The court dismissed the conversion claim because the allegations that Cayne kept or concealed Chalmers’s belongings were conclusory and included inconsistencies about the belongings and her car.

The court dismissed the constructive-trust claim without leave to amend because a constructive trust is an equitable remedy, not an independent cause of action.

Disposition

The court granted Cayne’s motion for judgment on the pleadings. It dismissed Causes of Action I, II, III, VI, VII, VIII, IV, V, IX, and X, while granting Chalmers leave to amend those claims. It dismissed Cause of Action XI, imposition of a constructive trust, without leave to amend. Chalmers’s amended complaint was due October 24, 2025. The court stated that, if she did not file an amended complaint by that date, judgment would be entered in Cayne’s favor on all claims. Chalmers could not add claims or defendants without first obtaining the court’s permission.