## Facts

- Speros Vryonis, Jr., a UCLA professor and director, dated Fereshteh R. Vryonis, an Iranian citizen and devout Shiah Muslim.
- Fereshteh stated she could not date without marriage due to religious beliefs; Speros said he was a “free man” and initially said he could not marry her.
- Fereshteh performed a private religious “Muta” ceremony in her apartment; no California marriage license was obtained and no California-authorized solemnization occurred.
- Fereshteh was unfamiliar with California marriage requirements and believed the ceremony created a valid marriage; Speros assured her it did.
- The parties kept the relationship secret and did not hold themselves out as married: they did not cohabit, maintained separate residences, did not tell friends or family, did not commingle finances, did not acquire joint property, and filed separate tax returns claiming single status.
- Speros continued dating other women; Fereshteh did not use his surname.
- After Speros announced he intended to marry another woman, Fereshteh sought dissolution and property/support rights based on putative spouse status.

## Issues

1. Whether Fereshteh qualified as a putative spouse by having a good-faith, objectively reasonable belief that she was validly married under California law based on a private religious ceremony and Speros’s assurances, despite noncompliance with statutory marriage formalities and absence of public marital conduct.

## Decision

- The Court of Appeal set aside the trial court’s finding of putative spouse status.
- The court held Fereshteh’s belief in a valid California marriage was not objectively reasonable on these facts.
- Due to procedural posture, the court granted extraordinary relief and ordered issuance of a peremptory writ.

## Legal Principles

- Putative spouse status requires both (1) a subjective good-faith belief in the existence of a valid marriage and (2) an objectively reasonable basis for that belief under California law.
- A belief grounded solely in private religious practice and a partner’s assurances is insufficient where the parties make no attempt to comply with California marriage licensing and solemnization requirements.
- Conduct inconsistent with a public marital relationship (secrecy, separate residences, separate finances, single tax filings, and not holding out as married) undermines objective reasonableness.
- The putative spouse doctrine is a limited equitable protection for those who believe they entered a lawful civil marriage but are prevented by a legal impediment; it cannot be used to circumvent California’s statutory marriage scheme or create a form of common-law marriage.

## Conclusion

The court denied putative spouse status because, given the complete lack of statutory compliance and the parties’ consistently nonmarital public conduct, Fereshteh could not reasonably believe she was validly married under California law.


In re Marriage of Vryonis, 248 Cal. Rptr. 807 (Cal. Ct. App. 1988)