In 1971, Michelle Marvin claimed that actor Lee Marvin, who was still married at the time they began living together, had promised to support her for the rest of her life. In the end, in Marvin v. Marvin, the California Supreme Court ruled that Michelle Triola Marvin had not proven the existence of a contract between herself and Mr. Marvin that gave her an interest in his property. Thus, the common law rule applied to the situation without alteration, and she took away from the relationship and the household what she brought to it.
The Court went on to explain that while the state abolished common law marriage in 1896, California law recognizes non-marital relationship contracts. These contracts may be express or implied, oral or writtenâ€”but they must be provable in any case. The contract may also provide for a sexual relationship as long as it is not a contract for sexual services. Eventually, the California Court of Appeal ruled that since Michelle Triola (later she changed her name) and Lee Marvin never had a contract, she was not entitled to any money.