Can a husband bring a constructive trust claim against his wife in a marital dissolution action?

Finally, the court in Askew v. Askew (1994) 22 Cal.App.4th 942, 28 Cal.Rptr.2d 284, held that a civil trial court lacked jurisdiction to consider a husband's suit to impose constructive trusts on alleged community real property because a marital dissolution action had already been filed by the wife. After the wife filed for divorce, the husband sued her for fraud, alleging that she lied to him before marriage about the existence of her affection and sexual attraction for him. In reliance on these misrepresentations, the husband alleged that he transferred title to various real properties in both their names as joint tenants and sought damages or recovery by way of constructive trust. Following a jury trial, judgment was entered for the husband, along with the imposition of constructive trusts on certain properties acquired after marriage.