## Facts

- Edward Spearman married Mary Spearman in Russell County, Alabama, on October 2, 1946; they had two daughters.
- Edward later moved to California and went through a marriage ceremony with Viva Spearman in Monterey County, California, on June 7, 1962.
- Edward was covered by a $10,000 group life insurance policy issued by Metropolitan Life Insurance Company under the Federal Employees’ Group Life Insurance Act (FEGLIA).
- Edward did not designate a beneficiary; under the policy’s default payment terms, the proceeds were payable to his “widow.”
- Edward died on October 1, 1969, while domiciled and employed in California.
- Both Mary (the first wife) and Viva (the second wife) claimed to be Edward’s “widow” entitled to the FEGLIA proceeds.
- Metropolitan Life filed a federal interpleader action and deposited the proceeds with the court, asking the court to determine the proper payee.
- The district court found no evidence of any legal proceeding dissolving Edward’s marriage to Mary (no divorce or annulment).
- Viva testified that she knew of the possibility that Edward’s marriage to Mary had not been dissolved before Viva’s ceremony with Edward.
- The district court concluded Mary was Edward’s lawful widow and awarded her the proceeds; Viva appealed.

## Issues

1. Under a FEGLIA group policy that pays benefits to the insured’s “widow” when no beneficiary is designated, does “widow” mean the lawful widow determined under state domestic-relations law?
2. Under California law, did Viva establish either (a) that Edward’s prior marriage to Mary was dissolved so that Viva’s marriage was valid, or (b) that Viva qualified as a putative spouse despite the invalidity of the second marriage?

## Decision

- The Fifth Circuit affirmed the judgment awarding the insurance proceeds to Mary.
- The court construed “widow” in the FEGLIA policy to mean “lawful widow” and looked to state law to identify the lawful widow.
- Applying California law, the court agreed that Mary rebutted the presumption favoring the validity of the later marriage by showing no divorce or annulment had terminated the Alabama marriage.
- Because Viva did not prove the first marriage was dissolved, the court treated Viva’s marriage as invalid.
- The court rejected Viva’s claim to recover as a California putative spouse because the record supported the finding that Viva lacked a good-faith and reasonable belief that her marriage to Edward was valid, given her awareness that a divorce from Mary might never have occurred.

## Legal Principles

- When a FEGLIA policy (and the statute) provides payment to a “widow” in the absence of a designated beneficiary, “widow” is read as “lawful widow.”
- Federal courts generally determine “lawful widow” status by reference to applicable state domestic-relations law.
- Under California law, a later marriage is presumed valid, but the presumption can be rebutted by evidence that a prior marriage was never dissolved; once rebutted, the party relying on the later marriage must prove dissolution of the earlier marriage.
- A California putative spouse is a party to a void marriage who entered it with a good-faith and objectively reasonable belief in its validity; knowledge that a prior marriage may still exist defeats that status.

## Conclusion

Because “widow” under the FEGLIA policy meant Edward Spearman’s lawful widow, and because California law treated Edward’s marriage to Viva as invalid in the absence of proof that his first marriage to Mary had been dissolved—and Viva also failed to qualify as a putative spouse—Mary Spearman was the only lawful widow and entitled to the policy proceeds.


Spearman v. Spearman, 482 F.2d 1203 (1973)