## Facts

- Curtis Jackson (professionally known as “50 Cent”) and Shaniqua Tompkins dated beginning in the mid-1990s, had a son together, and lived together at various times, but never married.
- Tompkins alleged that in September 1996—shortly before their son was born—Jackson made an oral promise that if she stayed with him and supported him until he “made it big” in entertainment, he would “take care of [her] for the rest of [her] life,” she would have “everything he owns,” and they would be “equal partners in all of his earnings,” even if they later separated.
- Tompkins claimed she agreed, in return, to provide household services and to raise their son.
- Tompkins asserted she provided a mix of support during the relationship, including financial help before Jackson obtained a record deal, buying items meant to help his image, and other assistance she described as physical, mental, and financial support.
- Tompkins also claimed she helped Jackson during his recovery after he was shot.
- The relationship eventually ended on poor terms. Tompkins sued Jackson seeking to enforce the alleged oral agreement and sought substantial monetary relief tied to Jackson’s wealth and future income.
- Jackson denied making the alleged promise and moved for summary judgment dismissing the complaint.

## Issues

1. Whether Tompkins’s account of Jackson’s oral statements—promising lifetime support and equal sharing of “everything” and “all earnings” once he “made it big”—was sufficiently definite to form an enforceable contract under New York law.
2. Whether the alleged oral promise was unenforceable under New York’s Statute of Frauds because it contemplated performance over Tompkins’s lifetime and other open-ended future obligations.
3. Whether Tompkins could recover under equitable theories (e.g., unjust enrichment, quantum meruit, constructive trust) based on the support, caregiving, and household services she claimed to have provided during the parties’ nonmarital relationship.

## Decision

- The court granted Jackson’s motion for summary judgment and dismissed Tompkins’s claims.
- Even crediting Tompkins’s description of what was said, the alleged promise was too vague and aspirational—phrased in terms such as “take care of [her] for the rest of [her] life,” “everything he owns,” and “equal partners in all earnings”—without objective, workable terms defining the parties’ obligations.
- The court concluded the asserted agreement was also not enforceable as an oral contract where the alleged commitment was for lifetime support and other continuing, future performance, placing it within the Statute of Frauds absent a writing.
- The court rejected Tompkins’s efforts to obtain compensation through equitable remedies, reasoning that the claimed services and support arose from the parties’ personal relationship and parenting arrangement and did not supply a legally sufficient basis to impose a wealth-sharing remedy or a trust-like interest in Jackson’s assets.

## Legal Principles

- A contract requires sufficiently definite terms; statements of affection or broad assurances (“I’ll take care of you for life,” “everything I own will be yours,” “equal partners in all earnings”) are not enforceable without clear, objective terms that allow a court to determine the parties’ duties and a remedy for breach.
- Under New York’s Statute of Frauds, an oral agreement that, by its terms, cannot be performed within one year (including a promise of lifetime support) is generally unenforceable without a signed writing.
- New York permits express agreements between unmarried partners, but such agreements are judged by ordinary contract rules; courts do not convert nonmarital relationships into quasi-marital property sharing based on generalized promises.
- Quasi-contract remedies (unjust enrichment/quantum meruit) require more than contributions that are part of a romantic relationship or ordinary family life; they do not substitute for a missing, enforceable agreement to share future income and assets.
- A constructive trust requires recognized equitable elements tied to specific property; it is not a vehicle for awarding an open-ended share of a defendant’s overall net worth or future earnings based on a failed personal relationship.

## Conclusion

The court entered summary judgment for Jackson, holding that the alleged oral promise of lifetime support and equal sharing of assets and earnings after he “made it big” was too indefinite to enforce and, in any event, was barred as an unwritten long-term agreement; the court also refused to use equitable remedies to award Tompkins a share of Jackson’s wealth based on support and services provided during their nonmarital relationship.


Tompkins v. Jackson, 880 N.Y.S.2d 876, 2009 WL 5213858 (2009)