Alienation of Affections Case Involving Songwriter Skylar Grey Going Forward
In today’s Mandel v. Hafermann, Magistrate Judge Jacqueline Scott Corley (N.D. Cal.) dismissed the great bulk of the claims brought by Todd Mandel, Grey’s ex-husband and ex-manager. (Grey is apparently a songwriter of considerable talents and success; she has cowritten with Eminem, and has written songs that were performed by Christina Aguilera, Celine Dion, Nick Jonas, and others. She has also performed guest vocals on songs by Dr. Dre, Nicki Minaj, and Macklemore.)
Mandel had sued for, among other things, defamation, based on statements made when Grey got a temporary restraining order against him, accusing him of “stalking her, hiding recording devices in her home, tracking her with a private investigator, and threatening her with violence.” That case and many related ones were thrown out; but the court allowed the alienation of affections claim to proceed, applying the law of Utah, one of the few states that still recognizes the tort:
[Mandel alleges as follows:] Mr. Taylor met Ms. Hafermann [Skylar Grey is her professional name -EV] and Mr. Mandel in 2016, and the three developed a friendship. After meeting them, Mr. Taylor, a California resident, would visit Mr. Mandel and Ms. Hafermann in Utah. Sometime between late 2016 and mid-2017 Mr. Taylor and Ms. Hafermann began having an extramarital affair. In May 2017, Ms. Hafermann moved from the residence she shared with Mr. Mandel in Park City, Utah to St. Helena, California, where she began to live with Mr. Taylor. On June 12, 2017, Ms. Hafermann filed for divorce to end her marriage with Mr. Mandel….
Turning to the relevant choice-of-law factors, the injury occurred in Utah, where Mr. Mandel lived while Mr. Taylor and Ms. Hafermann conducted their extramarital affair and where Ms. Hafermann
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