Bradley v. Bradley
208 Md. App. 249, 2012 Md. App. LEXIS 133, 56 A.3d 541 (2012)
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Rule of Law:
A claim for misrepresentation based on a party's false statement about their marital status is an independent tort action grounded in deceit and is not barred by a statute that abolishes the cause of action for breach of a promise to marry.
Facts:
- While married to another woman, Ronald L. Bradley, Jr. began a romantic relationship with Dara Lawrence Bradley.
- Ronald told Dara that he had been separated for years and had initiated divorce proceedings against his wife.
- In September 2006, Ronald announced that his divorce was final and presented Dara with a forged 'Judgment of Absolute Divorce' document.
- Relying on Ronald's representation that he was divorced, Dara married him in a ceremony in Las Vegas in April 2007.
- In 2008, Dara discovered through a search of the Maryland Judiciary Case Search website that Ronald had never actually divorced his first wife.
- When confronted, Ronald confessed that he was still married, causing Dara to suffer significant emotional distress requiring psychiatric treatment and medication.
- Prior to the discovery of the fraud, Dara had quit her job at Ronald's request to help care for his children.
Procedural Posture:
- Dara Lawrence Bradley filed a complaint for annulment against Ronald L. Bradley, Jr. in the Circuit Court for Baltimore County (a state trial court).
- Dara later amended her complaint to include tort claims for misrepresentation, intentional infliction of emotional distress, and battery.
- Following a jury trial, the jury returned a verdict in favor of Dara, awarding her a total of $469,000 in compensatory and punitive damages.
- The trial court entered judgment on the jury's verdict.
- Ronald filed a post-trial 'Motion for New Trial, Judgment Not Withstanding the Verdict, and to Alter or Amend Judgment,' which the trial court denied.
- Ronald (appellant) filed a timely appeal of the judgment to the Court of Special Appeals of Maryland (an intermediate appellate court), with Dara as the appellee.
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Issue:
Does Maryland's statutory prohibition against actions for breach of a promise to marry bar a separate tort claim for intentional and negligent misrepresentation based on a defendant's false statement that he was divorced?
Opinions:
Majority - Berger, J.
No. The statutory bar on actions for breach of promise to marry does not prohibit an independent tort claim for misrepresentation when the claim is based on a fraudulent statement about one's legal ability to marry. The court reasoned that the harm did not arise from a broken promise to marry, but from the deceitful misrepresentation of a present fact—that the appellant was divorced. Citing precedent from Miller v. Ratner and Vance v. Vance, the court distinguished between a non-actionable 'change of mind' case (breach of promise) and an actionable tort of deceit where a person is fraudulently induced to change their position based on a lie about the promisor's marital status. Here, the tort claims stemmed directly from the appellant's intentional conduct of falsely claiming he was divorced, not from a failure to follow through on a promise to marry; indeed, he went through with a sham wedding. Therefore, the misrepresentation claims were valid and distinct from the statutorily barred action.
Analysis:
This decision solidifies the distinction between non-actionable 'heart balm' torts, such as breach of promise to marry, and actionable torts like fraudulent misrepresentation. It clarifies that a statutory bar on the former does not shield a defendant from liability for the latter, even when the events occur within a romantic relationship centered on marriage. The ruling establishes a precedent in Maryland that one cannot use the abolition of breach-of-promise suits as a defense against claims of deceit regarding one's legal capacity to marry. This preserves a remedy for individuals who suffer tangible and emotional harm after being fraudulently induced into a void marriage, ensuring that the focus remains on the defendant's fraudulent conduct rather than on the plaintiff's lost marital expectations.
