When "Ladies' Man" was made in 1931, Francis was a more renowned star than Lombard (and would make several films with Powell, notably "One-Way Passage" in 1932). By 1939, when "In Name Only" was filmed, Carole was riding high, while Kay's star had waned.
Something similar took place in 1937, when Carole was making what turned out to be her final film at Paramount, "True Confession." Three years before, John Barrymore helped Lombard deliver a career-changing performance in "Twentieth Century," but by '37, age and alcoholism had diminished Barrymore into a has-been. Carole, who remembered what he had done for her (and the compliments he subsequently gave her), insisted he get a crucial supporting role.