Willis v. Willis

Summary

The Wyoming Supreme Court affirmed a judgment denying a woman $13,950 for roughly eight years of housekeeping, rooming-house, and cabaret services rendered while living with the defendant, while leaving intact the $600 loan award in her favor. It held that the divorce decree rejecting her common-law-marriage claim did not adjudicate whether she was the defendant's servant for pay, because that fact was immaterial and collateral to the divorce action, and that no estoppel arose from the defendant's inconsistent divorce pleadings absent reliance. On the merits, it held that a woman who knowingly lives in illicit relations cannot recover on an implied contract for services incidental to that relationship, and the evidence sustained the trial court's findings against her on good faith and on the existence of an express employment contract.