Ceja v. Rudolph & Sletten, Inc. - 56 Cal. 4th 1113, 158 Cal. Rptr. 3d 21, 302 P.3d 211 (2013)

Rule:

Code Civ. Proc., § 377.60, subd. (b), defines a "putative spouse" as the surviving spouse of a void or voidable marriage who is found by the court to have believed in good faith that the marriage to the decedent was valid. The good faith inquiry is a subjective one that focuses on the actual state of mind of the alleged putative spouse. While there is no requirement that the claimed belief be objectively reasonable, good faith is a relative quality and depends on all the relevant circumstances, including objective circumstances. In determining good faith, the trial court must consider the totality of the circumstances, including the efforts made to create a valid marriage, the alleged putative spouse's personal background and experience, and all the circumstances surrounding the marriage. Although the claimed belief need not pass a reasonable person test, the reasonableness or unreasonableness of one's belief in the face of objective circumstances pointing to a marriage's invalidity is a factor properly considered as part of the totality of the circumstances in determining whether the belief was genuinely and honestly held. In re Marriage of Vryonis, 202 Cal. App. 3d 712, 248 Cal. Rptr. 807 (1988), and its progeny are disapproved to the extent they are inconsistent with the views expressed herein.

Facts:

Plaintiff filed a wrongful death action against defendant, claiming she was the putative spouse of decedent. The trial court granted defendant's motion for summary judgment. It found the undisputed material facts established that plaintiff did not have an objectively reasonable good faith belief in the validity of her marriage to decedent. The Court of Appeal reversed, holding that Code Civ. Proc., § 377.60's requirement of a good faith belief referred to the alleged putative spouse's subjective state of mind. According to the Court of Appeal, plaintiff's claims that she believed and acted as if her marriage were valid and that she had not read the marriage license or the final divorce papers, if found credible by the trial court, could support a finding of a good faith belief and establish putative spouse status.

Issue:

Did the Code Civ. Proc., § 377.60's requirement of a good faith belief refer to the alleged putative spouse's subjective state of mind? 

Answer:

Yes.

Conclusion:

The Supreme Court affirmed the judgment of the Court of Appeal, holding that Code Civ. Proc., § 377.60, contemplated a subjective standard that focused on the alleged putative spouse's state of mind to determine whether he or she maintained a genuine and honest belief in the validity of the marriage. Good faith must be judged on a case-by-case basis in light of all the relevant facts, such as the efforts made to create a valid marriage, the alleged putative spouse's background and experience, and the circumstances surrounding the marriage, including any objective evidence of the marriage's invalidity. Under this standard, the reasonableness of the claimed belief was a factor properly considered along with all other circumstances in assessing the genuineness of that belief. The good faith inquiry, however, did not call for application of a reasonable person test, and a belief in the validity of a marriage need not be objectively reasonable. The trial court granted summary judgment based on the erroneous assumption that good faith must be tested under the reasonable person standard.