## Facts

- Ida H. Coats and Lee B. Coats married in November 1887 and cohabited for over 18 years.
- Ida performed household work and assisted with Lee’s farming and later business efforts.
- In 1897, Lee entered a partnership buying and selling horses and mules.
- In January 1906, Lee obtained a judgment annulling the marriage based on Ida’s physical incapacity; the decree did not address property.
- During the relationship, Lee accumulated nearly all of his assets, worth about $70,000 at annulment; Ida had no separate property and received none after annulment.
- Ida filed a separate equity action seeking a division of property acquired during the relationship.
- The trial court found the property was accumulated after the marriage through the parties’ joint efforts and awarded Ida $10,000; Lee appealed.

## Issues

1. Whether the prior annulment decree barred Ida’s later property-division action under res judicata or estoppel.
2. Whether a spouse who entered a voidable marriage in good faith may obtain an equitable share of property acquired through joint efforts during the relationship, despite an annulment declaring the marriage void from inception.

## Decision

- The annulment decree did not bar the later action because property rights were not placed in issue or adjudicated in the annulment proceeding.
- Equity may award a good-faith spouse a fair share of property accumulated during the relationship, even though the marriage is annulled as void from the beginning.
- The $10,000 award was within the trial court’s equitable discretion given the parties’ contributions, the source of the assets, and Ida’s lack of property.
- The judgment was affirmed.

## Legal Principles

- Claim preclusion applies only to matters actually litigated or necessarily determined; an annulment decree that does not address property does not decide property rights by implication.
- The legal effect of annulment (treating the marriage as void from inception) does not prevent equitable relief to avoid unjust deprivation where property was acquired through the parties’ joint efforts during a good-faith marital relationship.
- A spouse who enters a voidable marriage in good faith and is later subjected to annulment at the other party’s instance may recover an equitable share of property accumulated during the relationship.

## Conclusion

A prior annulment judgment that does not litigate or decide property rights does not preclude a later equitable action for property division, and a good-faith spouse may receive a fair share of assets accumulated through joint efforts during the putative marriage notwithstanding the annulment.


Coats v. Coats, 160 Cal. 671 (Cal. 1911)