## Facts

- Thomas A. Gionis and Aissa Wayne Gionis married on February 14, 1986, and had an infant daughter.
- In June 1987, Aissa filed petitions for legal separation and dissolution, seeking sole custody, child support, and spousal support.
- The parties later proceeded on the dissolution petition and stipulated the court had jurisdiction over both parties for dissolution purposes as of June 1987.
- The custody dispute was highly contentious, and other issues (support and property) were expected to require extended litigation.
- On January 29, 1988, Thomas moved to bifurcate marital status from remaining issues, declaring the marriage had irretrievably broken down, reconciliation was impossible, and prompt status termination was needed to conduct investments and obtain credit without community-property complications.
- Aissa opposed bifurcation on procedural grounds and did not identify substantive prejudice from entering a status-only judgment.
- The superior court denied bifurcation, stating there was no “compelling reason” given the relatively short time since filing and making remarks reflecting personal moral views about sexual conduct and remarriage before dissolution.
- Thomas sought writ relief, contending the denial was an abuse of discretion.

## Issues

1. Whether the superior court abused its discretion by denying bifurcation of marital status from custody, support, and property issues in a dissolution action.

## Decision

- The Court of Appeal granted writ relief and directed the superior court to vacate its order denying bifurcation.
- The court ordered the superior court to grant bifurcation and enter a status-only judgment dissolving the marriage.
- The court held the trial court applied an incorrect standard by requiring a “compelling reason” and by relying on irrelevant moral considerations.
- The court emphasized the absence of any showing of substantive prejudice by the spouse opposing bifurcation.

## Legal Principles

- California dissolution policy permits severing and adjudicating marital status separately from collateral disputes to avoid prolonging termination of the marital relationship.
- A spouse seeking bifurcation of marital status need not show a “compelling need”; a good-faith declaration of irretrievable breakdown plus practical personal or financial reasons can be sufficient.
- The spouse opposing bifurcation bears the burden to show specific, substantive prejudice or other legally cognizable reasons to keep status joined to remaining issues.
- Trial courts abuse discretion when they apply a heightened, incorrect standard for bifurcation or base rulings on personal moral judgments rather than legally relevant factors.

## Conclusion

The Court of Appeal required bifurcation and entry of a status-only dissolution judgment because the moving spouse made an adequate good-faith showing, the opposing spouse failed to show prejudice, and the trial court improperly demanded a “compelling” justification while relying on irrelevant moral considerations.


Gionis v. Superior Court, 202 Cal. App. 3d 786 (Cal. Ct. App. 1988)