Action based on 'Marvin Agreement' Must be Commenced within 1 Year after Decedent's Death

In Marvin v. Marvin (1976) 18 Cal.3d 660, where a woman claimed she lived with a man for 6 years and assisted him in consideration of his verbal promise to share all earnings, the California Supreme Court held that such an agreement is enforceable. In this case, McMackin v. Ehrheart, the California appellate court held that 'a decedent?s promise to leave her cohabitant a life estate in real property is governed by the one-year statute of limitations of Code of Civil Procedure section 366.3.'
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