## Facts

- Nancy Ceja and Robert Ceja participated in a religious wedding ceremony after obtaining a marriage license.
- At the time of the ceremony, Robert’s divorce from his prior spouse was not yet final, making the marriage legally void as bigamous.
- Nancy knew a divorce was pending but asserted she did not know it was not final when they married.
- The marriage license reflected Robert’s representation that he had never been married.
- Nancy later transmitted a copy of the divorce judgment for benefits-related paperwork but claimed she did not read it closely and did not notice the divorce finalization date post-dated the ceremony.
- Robert died in a workplace accident while employed by Rudolph & Sletten, Inc. (R&S).
- Nancy filed a wrongful death action against R&S and claimed standing as a dependent “putative spouse” under California Code of Civil Procedure § 377.60(b).
- The trial court granted summary judgment for R&S, concluding Nancy’s belief in the marriage’s validity was not objectively reasonable.

## Issues

1. Whether Code of Civil Procedure § 377.60(b)’s requirement that the claimant “believed in good faith that the marriage was valid” imposes an objective reasonableness test or a subjective state-of-mind inquiry.
2. Whether summary judgment was proper on the record regarding Nancy’s putative-spouse status.

## Decision

- The Court of Appeal reversed the summary judgment and remanded.
- The court held that § 377.60(b) requires a subjective inquiry into whether the claimant actually believed the marriage was valid and held that belief honestly and sincerely, without collusion or fraud.
- The trial court erred by applying an objective reasonableness standard.
- Triable issues existed as to what Nancy understood about the status of the prior divorce and whether her asserted belief was genuinely held.

## Legal Principles

- Under Code of Civil Procedure § 377.60(b), a “putative spouse” is a party to a void or voidable marriage who believed in good faith that the marriage was valid.
- “Believed in good faith” under § 377.60(b) focuses on the alleged putative spouse’s actual state of mind, not on whether the belief was objectively reasonable.
- Good faith requires an honest, genuine, and sincere belief; credibility and surrounding circumstances may be evaluated to determine whether that belief existed.
- Summary judgment is improper when disputed facts bear on whether the claimant subjectively held a good-faith belief in the validity of the marriage.

## Conclusion

The Court of Appeal held that putative-spouse standing for wrongful death under Code of Civil Procedure § 377.60(b) turns on the claimant’s subjective, sincerely held belief in the marriage’s validity; because disputed facts existed under that standard, summary judgment for the employer was reversed and the case was remanded.


Ceja v. Rudolph & Sletten, Inc., 194 Cal. App. 4th 584 (Cal. Ct. App. 2011)