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  • Writer's pictureCheryl Anne Stapp

Lost Love in the Early 20th Century

How much does it cost to ruin romance? Substantial money, apparently, because that’s what four women hoped to gain in 1914-15 when each filed suit in Los Angeles Superior Court, for what was, at the time, a legal recourse in California termed “alienation of affection.”

The largest of the four cases was that of movie actress Miss Maude Armfield against Bryant Howard, asking $500,000 in damages for his failure to marry her. The second suit was that of Mrs. Louise Hayward against her millionaire father-in-law, Dr. Henderson Hayward, asking $100,000 in damages for his role in alienating the affections of her husband, Lester Hayward.

The third suit, filed by Miss Marguerite Coffey, a young woman, sought damages of $50,000 from A. G. Gardner—an elderly businessman—for his refusal to marry her. In the fourth case, Miss Florence Meyer asked $100,000 from Richard O’Neill Jr., a wealthy San Diego man and member of a prominent California family; Miss Meyer alleging that O’Neill “won her heart and affections” and then rejected them.

Each case was different. The charges of lost love were the only things in common, but Maude Armfield’s story was the most unusual.

As Maude told it in court, she had been a chorus girl in 1909, in a troupe that appeared in a San Diego theater. Bryant Howard, scion of a wealthy family and young man about town, saw the performance, was instantly love-struck, and soon proposed. Their wedding ceremony was performed in Howard’s home . . . but there was one small hitch. Howard’s first wife, who claimed he had divorced her without her knowledge, went to court and had the divorce set aside.

This left Bryant Howard with two wives and a possible prosecution for bigamy; but he saw a way out. The first wife claimed he offered to marry her a second time if she agreed to an annulment of their marriage and a separation until a proper divorce could be secured. She agreed, the annulment released Howard’s thorny situation with Maude; the first wife sued for divorce and got it. Now Howard had no wife at all.

Maude Armfield then went with Howard to a hunting lodge in the mountains in the northern part of the state, where they “lived in harmony with nature,” until winter came and they were snow-bound for seven months. A long and hazardous trip through mountain passes, with the help of Indians, became necessary. A child was born, but Bryant Howard disowned it. Maude begged him to marry her and he refused; the jury awarded her $40,000.

Mrs. Louise Hayward’s experience was different. Lester Hayward was a soldier without funds when she met him in Washington DC, and Louise claimed she helped him financially in buying his release from the army. After their marriage they moved to Los Angeles, where Lester had told her his wealthy father would start him in business. Mrs. Hayward testified that not only were the friendly relations she sought with her husband’s family denied—and even worse, her husband’s father gave Lester money and railroad tickets to get out of the city. He departed, but Louise kept the letters they exchanged while apart, presented in court as proof of the great love they shared; a love, she said, the defendant Dr. Henderson Hayward had attempted to sour.

Unfortunately for Louise, the prevailing notion of acceptable courtship conduct doubtless influenced the outcome when Lester testified they had met through a newspaper advertisement for a husband, which she had placed. Further, they had indulged in a physical relationship before the wedding. The award of $25,000 to Mrs. Hayward in the first trial (who, recall, was asking $100,000) was supplanted by a verdict of nothing, in the second go-round, with just three of twelve jurors believing she was entitled to compensation. As of March 1915, she was seeking a third trial.

Miss Marguerite Coffey, a beautiful singer and musician of some note, had met her elderly suitor at musical fetes. Her complaint seeking $50,000 from Mr. Gardner claimed he had refused to keep the promise to marry they had made in November, 1914. He, however, had a different story. Yes, he had originally been most willing, writing these words and signing them: “I promise to take unto me Marguerite Coffee as my lawful wife, for better, for worse, for richer, for poorer, in sickness and in health, and I promise to be your faithful husband till death do us part.” However, when he penned the same pledge for her to sign—promising to be his wife—she scribbled something she wouldn’t show him, and refused to return the papers he had given her.

His defense: “I deny that she was ever ready and willing to marry me.” As of March, 1915, neither party had made a move to proceed.

Miss Florence Meyer’s suit against Richard O’Neill alleged that they promised to marry in August, 1914; that three months later in November, he wrote her that she should look for someone else, because his financial condition would not permit him to marry. Florence, who knew Richard was part owner of extensive ranch properties, felt otherwise: his financial condition should be no barrier to their marriage. Her complaint alleged that for several years O’Neill had showered her with attention, soliciting her affections, which did arouse love in her heart. Moreover, he wrote her innumerable letters, all couched in the most endearing and affectionate terms. His sudden change of heart was devastating because, having believed in the sincerity of his intentions in August 1914, Florence had quite naturally announced her soon-to-be marriage to her friends and acquaintances. Now, of course, she was subject to ridicule—thus her lawsuit for breach of promise, a balm to her wounded heart.

In October, 1915, an item in the Los Angeles Herald announced that the Meyer/O’Neill $100,000 breach of promise suit would not be tried because a settlement had been reached that was satisfactory to Miss Meyer. In return, she agreed to return some 250 love letters to Mr. O’Neill.

Well, that was then—when women didn’t have the vote, when few women could support themselves adequately, when public sentiment was more sympathetic to feminine frailties. Times and social mores have changed; today women no longer drag men into court for breaking a promise to marry. California is one of 42 states that have abolished actions for alienation of affection, a tort law the United States inherited as part of English common law, once described as “an anachronistic holdover from a bygone era.”

And, of the states that still allow an alienation of affections suit, the charges filed must be against a third person alleged to be responsible for destroying an existing marital relationship in which love was present to some degree —typically, but not always, a spouse’s partner in adultery—not against the lost loved one themselves.

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