Ceja v. Rudolph & Sletten, Inc.
Supreme Court of California
302 P.3d 211 (Cal. 2013)
After her husband Robert's death, Nancy Ceja (plaintiff) sued as his putative spouse for wrongful death against Rudolph & Sletten (defendant), which argued Nancy lacked standing because Robert's prior marriage hadn't been finalized when he and Nancy married; the marriage license incorrectly stated Robert had no prior marriage, which Nancy signed without reading, and she claimed Robert had refused to discuss the issue, leaving her genuinely unaware his prior marriage remained undissolved and believing at all times her own marriage was valid. The trial court granted Rudolph summary judgment, finding Nancy didn't meet the putative-spouse statute's good-faith requirement, and the court of appeal reversed; Rudolph petitioned for review.
Whether the good-faith belief requirement for putative-spouse status — that the individual believed in good faith the marriage was valid — is measured by a subjective standard based on the individual's actual state of mind, or by an objective reasonableness standard.