## Facts

- William Lester Stahl married Mrs. Stahl, who was the custodial parent of three children from a prior marriage.
- The family lived together during the marriage until the spouses separated in October 1981.
- Mrs. Stahl filed a petition for dissolution on October 16, 1981.
- In March 1982, Mrs. Stahl began receiving public assistance from the Department of Social and Health Services (DSHS) for the children.
- As a condition of receiving assistance, Mrs. Stahl assigned to DSHS her rights to support for the children.
- In August 1982, DSHS served Stahl with a Notice and Finding of Financial Responsibility and sought support for the stepchildren.
- After an administrative hearing, an administrative law judge (and agency review) determined Stahl was obligated to support the stepchildren until the marriage was legally dissolved.
- Stahl sought judicial review. On summary judgment, the superior court reversed, reasoning that after separation Stahl was a “noncustodial stepparent” with no duty to support the children, and it awarded him attorney’s fees.
- The marriage was dissolved by decree on February 14, 1983.
- DSHS appealed the superior court’s summary judgment.

## Issues

1. Under RCW 26.16.205, does a stepparent’s statutory obligation to support stepchildren end upon separation, or does it continue until the legal termination of the marriage?
2. Did the superior court err by reversing the DSHS administrative determination on the ground that Stahl’s support duty ended when the spouses separated?

## Decision

- The Court of Appeals reversed the superior court’s summary judgment.
- The court held that “termination of the relationship of husband and wife” in RCW 26.16.205 means a legal end to the marriage (such as dissolution or death), not mere separation.
- Because Stahl’s marriage to the children’s mother continued until the dissolution decree, his statutory duty to support his stepchildren continued through that date.
- The reversal reinstated the agency’s determination that Stahl was responsible for support through the dissolution.

## Legal Principles

- RCW 26.16.205 makes the expenses of the family and the education of the children, including stepchildren, chargeable to either spouse; for stepchildren, the obligation ceases upon termination of the husband-wife relationship.
- For purposes of RCW 26.16.205, “termination of the relationship of husband and wife” requires a legal end to the marriage; separation does not change marital status and does not end the statutory duty.
- Prior Washington decisions construing similar statutory language (including State v. Gillaspie) support reading “termination” as dissolution or death rather than separation.
- Van Dyke v. Thompson did not displace Gillaspie’s reading of RCW 26.16.205 in this context; the court treated Gillaspie and related authority as controlling on when the statutory duty ends.

## Conclusion

The Washington Court of Appeals held that RCW 26.16.205 obligates a stepparent to support stepchildren until the marriage is legally terminated, so Stahl’s duty did not end when he and his wife separated; it continued until the dissolution decree, and the superior court’s contrary summary judgment was reversed.


Stahl v. Department of Social and Health Services, 717 P.2d 320 (1986)