What This Case Means to You! Putative Spouse

In California, questions of marriage validity often arise during emotionally and legally complex situations, especially following death or divorce. If someone believes they were legally married, but the marriage turns out to be invalid, can they still claim spousal rights? This situation calls for an understanding of the putative spouse doctrine, a legal framework that protects individuals who enter into marriage in good faith, even if that marriage is legally void.

This blog explores the landmark California Supreme Court case Ceja v. Rudolph & Sletten, Inc. (2013), which reshaped the standards for determining whether someone qualifies as a putative spouse. It also breaks down how this decision affects claims for wrongful death, estate rights, and more, especially in cases where the legal marriage is questioned after one party’s death.

Ceja v. Rudolph & Sletten, Inc. (2013)

Fourth in a series of case reviews by Russell H. Thaw

Ceja v. Rudolph & Sletten, Inc. (2013) 56 Cal. 4th 1113, 158 Cal.Rptr 3d 21, 302 P.3d 211, wherein the California Supreme Court announces a new standard for the finding of “Putative Spouse” status.

FACTS: Nancy and Robert Ceja were married in a church ceremony. Four years later, Robert was killed in a work-related accident. Before Nancy could sue Robert’s employer for wrongful death, she learned the marriage was void because the wedding had taken place a few months before Robert’s divorce from his first wife was final. Robert’s employer moved for summary judgment, claiming Nancy did not qualify as a putative spouse. The trial court agreed and granted summary judgment in favor of Robert’s employer. In applying an objective test for the finding of putative status, the trial court found it was not objectively reasonable for Nancy to have believed her marriage was invalid. A California appeals court reversed the trial court, and the California Supreme Court affirmed the court of appeals.

What Is a Putative Spouse in California Law?

A putative spouse is a person who has a genuine, honest belief that they are legally married, even if the marriage turns out to be void due to a legal impediment such as bigamy or failure to properly dissolve a prior marriage.

Under California Family Code §2251, such individuals are granted equitable relief and can access the legal rights typically afforded to lawful spouses, including rights to property, benefits, and legal claims, such as wrongful death or inheritance.

The Legal Shift: From Objective to Subjective Test

The Objective Test (Pre-Ceja)

Before the Ceja ruling, courts used an objective standard: would a reasonable person, given the same facts, believe the marriage was valid? This meant that the burden of proof was not on the individual’s intent but on whether their belief was justifiable from a third-party legal perspective.

The Subjective Test (Post-Ceja)

The California Supreme Court ruled in Ceja that the correct standard is subjective. What matters is whether the person believed, in good faith, that they were married. The focus shifted from societal or judicial perceptions to the personal conviction and behavior of the individual claiming putative spouse status.

This ruling overturned In re Marriage of Vryonis (1988), which held that an objective test should apply.

Semantic Clarification: What Does “Subjective Belief” Mean in Legal Context?

The term “subjective belief” is pivotal in understanding the Ceja decision. Rather than asking whether a judge believes the facts support a marriage, the court now examines whether Nancy’s behavior and life choices consistently reflected her belief that she was married. This includes shared finances, social identification as spouses, and ceremonial practices, all of which were considered in Nancy’s favor.

Practical Legal Consequences of the Ceja Decision

The Ceja case has far-reaching implications:

• Wrongful Death Claims: As in Nancy’s case, a putative spouse can sue for wrongful death.
• Probate and Estate Rights: They may inherit under intestate succession.
• Community Property Division: Assets acquired during the “marriage” may be divided as if the marriage were valid.
• Employment Benefits and Insurance: A putative spouse can claim survivor benefits under employment or government plans.

How Putative Spouse Doctrine Interacts with Other Laws

This doctrine intersects with several other legal areas:

• Marriage Annulment: Where a marriage never legally existed due to fraud or prior undissolved marriages.
• Community Property Law: Especially in California, where equitable division is tied to the marital timeline.
• Spousal Support and Alimony: Even without a valid marriage license, a putative spouse may be entitled to support.

The doctrine reflects the courts’ intent to avoid punishing innocent parties who enter into a marriage with honest intentions.

Frequently Asked Questions

What qualifies someone as a putative spouse?

A person who enters into marriage with the sincere belief that it is valid, despite a legal flaw, may qualify.

Can I receive spousal benefits if my marriage is declared void?

Yes, if you meet the subjective good faith requirement established by Ceja, you can qualify for many of the same benefits.

Does this doctrine apply only in California?

No, other states may have similar doctrines, but California’s version is particularly robust due to its emphasis on equity.

Can both parties in a void marriage be considered putative spouses?

Yes, courts can declare both parties as putative spouses if both held a sincere belief in the marriage’s validity.

How is “good faith” determined?

By evaluating the behavior, actions, and intentions of the person claiming putative spouse status, such as cohabitation, shared finances, and community reputation.

Limitations and Legal Exceptions to the Doctrine

While Ceja broadened the application of the putative spouse doctrine, not all claims succeed. Situations where both parties knew the marriage was invalid or where the claimant was deceptive may disqualify a person. In such cases, courts will consider intent, knowledge of the legal defect, and surrounding circumstances.

Furthermore, if a person knowingly marries someone who is still legally married, even if the other spouse insists they are “almost divorced,” the belief may not be deemed reasonable or honest.

Contact Reape Rickett for Trusted Legal Guidance

At Reape Rickett, we understand the complexities of family law and fight to protect our clients’ rights, even in legally ambiguous situations. Whether you’re facing challenges with a void marriage, wrongful death claims, or property disputes, our attorneys bring unmatched experience and precision to your case.

Schedule a confidential consultation today and get expert legal advice rooted in deep case knowledge and proven courtroom success.

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