## Facts

- Nancy Ceja and Robert Ceja participated in a church wedding ceremony in September 2003.
- At the time of the ceremony, Robert’s prior marriage dissolution was not yet effective, rendering the new marriage void.
- The marriage license indicated no prior marriages for Robert; Nancy signed the license and later said she did not read it and that Robert completed it.
- A notice of entry of dissolution judgment was mailed to the couple’s home in December 2003 and stated neither party could remarry until the judgment’s effective date.
- Nancy later faxed that dissolution notice to Robert’s union for insurance purposes.
- About four years after the ceremony, Robert died in a work-related construction accident.
- Nancy filed a wrongful-death action against Rudolph & Sletten, Inc., asserting standing as Robert’s “putative spouse” under Code of Civil Procedure § 377.60(b).

## Issues

1. For putative-spouse status under Code of Civil Procedure § 377.60(b), is “good faith” measured by an objective reasonableness standard or by the claimant’s subjective, honest belief that the marriage was valid?
2. If the correct standard is subjective, may a court still consider objective reasonableness, and for what purpose?
3. Did the trial court apply the correct legal standard in granting summary judgment against the claimant’s putative-spouse standing?

## Decision

- The California Supreme Court held that § 377.60(b)’s “believed in good faith” requirement is a subjective inquiry into the claimant’s actual, honest, and sincere belief that the marriage was valid.
- The Court held that objective reasonableness is not an element of putative-spouse status, but may be considered as evidence bearing on credibility and sincerity.
- The Court affirmed the Court of Appeal’s reversal of summary judgment because the trial court used an objective reasonableness test.
- The case was remanded for further proceedings applying the subjective good-faith standard, with disputed facts to be resolved under that framework.

## 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” refers to the claimant’s subjective state of mind: whether the claimant actually and sincerely believed in the marriage’s validity.
- Objective reasonableness is relevant only as circumstantial evidence to evaluate whether the asserted belief was genuinely and honestly held.
- Summary judgment is improper when the court applies an incorrect legal standard to the putative-spouse inquiry and the record contains disputed facts bearing on the claimant’s subjective belief.

## Conclusion

The court ruled that wrongful-death standing as a putative spouse under Code of Civil Procedure § 377.60(b) depends on the claimant’s subjective, honest belief in the marriage’s validity, with reasonableness serving only as evidence of sincerity, and it affirmed reversal of summary judgment entered under an objective test.


Ceja v. Rudolph & Sletten, Inc., 56 Cal. 4th 1113 (Cal. 2013)