## Facts

- Claudette Knott entered a marriage with Langston Knott in California, unaware he was still legally married to another woman.
- Knott and Langston lived together as husband and wife for 22 years and had four children.
- After learning of the prior undissolved marriage, Knott obtained an annulment under California law.
- When Langston began receiving Social Security benefits, Knott applied (Oct. 11, 1996) for divorced spouse’s benefits on his earnings record.
- An ALJ denied the claim, reasoning the marriage was void, did not satisfy the ten-year duration requirement, and Knott was not a “divorced wife” under the Act and regulations.
- The Appeals Council denied review (Mar. 23, 2002), making the ALJ decision final; Knott sought judicial review under 42 U.S.C. § 405(g).
- On cross-motions for summary judgment, Knott argued she qualified as a putative spouse under California law and a deemed valid spouse under federal law (including 42 U.S.C. § 416(h)(1) and 20 C.F.R. §§ 404.331, 404.345, 404.346).

## Issues

1. Whether a claimant who entered a bigamous marriage in good faith may qualify for divorced spouse’s benefits as a putative spouse under California law and a deemed valid spouse under the Social Security Act, despite the marriage’s formal invalidity.
2. Whether an annulment and/or a residence or “living with” requirement bars entitlement to divorced spouse’s benefits under the deemed-spouse framework.

## Decision

- The court granted Knott’s motion for summary judgment, denied the Commissioner’s cross-motion, and remanded for an award of benefits.
- The court held Knott qualified as a putative spouse under California law because she entered the marriage in good faith and the doctrine applies to void or voidable marriages.
- The court held Knott met the federal deemed valid spouse requirements because the marriage was invalid due to a legal impediment unknown to her and she lived with Langston in good-faith belief of a valid marriage.
- The court rejected the ALJ’s conclusion that the void/annulled status prevented satisfaction of the ten-year duration requirement, treating the 22-year putative marriage as meeting the requirement for divorced spouse’s benefits.
- The court rejected the Commissioner’s reliance on a “living with” requirement, concluding it did not apply to divorced spouse’s benefits.
- Because the record was fully developed and supported only one result, the court ordered benefits rather than further administrative proceedings.

## Legal Principles

- Judicial review under 42 U.S.C. § 405(g) asks whether the agency applied proper legal standards and whether the decision is supported by substantial evidence on the record as a whole.
- Under California’s putative spouse doctrine, a party who enters a marriage in good faith, unaware of a legal impediment, may be treated as a spouse for the period of the relationship even if the marriage is void and later annulled.
- Under 42 U.S.C. § 416(h)(1) and implementing regulations, a claimant may be treated as a spouse for Social Security purposes where a purported marriage was invalid due to a legal impediment, so long as the claimant entered in good faith without knowledge of the impediment.
- For divorced spouse’s benefits, an annulment and formal state-law invalidity do not automatically defeat eligibility where the claimant otherwise satisfies federal deemed-spouse requirements and the duration requirement is met by the good-faith marital relationship.
- A regulatory “living with” requirement applicable to certain spousal benefits does not bar entitlement to divorced spouse’s benefits.

## Conclusion

The court set aside the agency’s denial and ordered an award of divorced spouse’s benefits, holding that a long-term, good-faith marital relationship can satisfy the Social Security Act’s deemed-spouse framework and the duration requirement even when the marriage was bigamous and later annulled, and that co-residence at application is not required for divorced spouses.


Knott v. Barnhart, 269 F. Supp. 2d 1228 (E.D. Cal. 2003)