## Facts

- Jeanne Brandon Anastasi sued Joseph Anastasi in New Jersey Chancery, alleging he promised to provide her “all of her financial support and needs for the rest of her life” arising from their nonmarital cohabitation.
- The defendant removed the action to federal court based on diversity jurisdiction.
- In an earlier federal ruling in the same litigation, the court treated the claim as an ordinary contract dispute outside the domestic-relations exception, relying on then-existing New Jersey authority.
- After removal, the New Jersey Supreme Court decided *Crowe v. DeGioia*, recognizing a substantial state interest in consensual “live-in” relationships and authorizing equitable remedies resembling matrimonial relief.
- The district court reconsidered, on its own initiative, whether the domestic-relations exception required remand in light of the intervening state decision.

## Issues

1. Whether a diversity case seeking enforcement of an alleged lifetime-support promise between former unmarried cohabitants falls within the domestic-relations exception to federal jurisdiction.
2. Whether, under New Jersey law as clarified by *Crowe v. DeGioia*, adjudicating such a claim would require domestic-relations-type inquiries and remedies that federal courts traditionally decline to undertake.

## Decision

- The court held the action fell within the domestic-relations exception to diversity jurisdiction.
- The court applied a two-part inquiry: (1) whether the state has a significant interest in the relationship comparable to marriage or parent-child relations, and (2) whether resolution requires the kinds of inquiries characteristic of domestic-relations adjudication.
- Relying on *Crowe*, the court found New Jersey had expressed a strong, specialized interest in regulating and remedying disputes arising from cohabiting relationships.
- The court concluded the case would require examination of the parties’ relationship, expectations, contributions, and financial circumstances, and could entail ongoing support-type relief rather than a fixed commercial damages award.
- The case was remanded to the Superior Court of New Jersey, Chancery Division.

## Legal Principles

- The domestic-relations exception bars federal diversity jurisdiction when a dispute implicates a state’s marriage-like relational interests and requires domestic-relations-type factual inquiries and remedial supervision.
- Labels in the pleadings (e.g., “contract”) do not control; courts look to the substance of the dispute and the nature of the relief and inquiries required.
- Intervening state high-court authority that recharacterizes cohabitation-support claims as warranting equitable, support-like remedies can shift a case from contract treatment to domestic-relations treatment for jurisdictional purposes.
- Federal courts may remand removed diversity cases when the exception applies, recognizing state courts’ primary responsibility for developing and applying domestic-relations policy.

## Conclusion

The district court determined that, after New Jersey’s recognition of marriage-like state interests and equitable support remedies for cohabitants, the plaintiff’s lifetime-support claim required domestic-relations adjudication and therefore belonged in state court rather than federal diversity jurisdiction.


Anastasi v. Anastasi, 544 F. Supp. 866 (D.N.J. 1982)