Strasberg

Anna Strasberg, as the present sole beneficiary of Marilyn Monroe’s personal effects under Ms. Monroe’s will and as administrator of her estate, brought suit for conversion, unjust enrichment, injunctive relief and a declaration of a constructive trust to prevent an auction of certain of Ms. Monroe’s personal effects. A jury found Marilyn Monroe’s business manager and assistant had converted these items after Ms. Monroe’s death. Accordingly, the trial court imposed a constructive trust on the personal effects and ordered the auction house to return the items to Anna Strasberg. The business manager’s successor in interest and the auction house appeal from the judgment and the trial court’s denial of their motion for judgment notwithstanding the verdict. We affirm.

Facts and Proceedings Below

Marilyn Monroe died on August 5, 1962, in Los Angeles, California. Ms. Monroe’s last will and testament was probated in New York and admitted for ancillary proceedings in California in January 1963. In her will Ms. Monroe made provisions for certain friends and family members. Ms. Monroe bequeathed Lee Strasberg, her acting coach and trusted confidant, “all of my personal effects and…