A man who moved into his fiancée's house and, on her promise to "make this house our home," invested $36,000 to improve the property before she filed for divorce is not entitled to reimbursement, according to a judge who said he was loath to expand "the constructive trust doctrine as a substitute for equitable distribution."

Acting Supreme Court Justice Richard Dollinger in Rochester (See Profile) rejected Dale Frederick's unjust enrichment and constructive trust claims, which arose in the context of a marriage that lasted only a few months.