Ceja v. Rudolph & Sletten, Inc.

194 Cal. App. 4th 584, 125 Cal. Rptr. 3d 98 (2011)

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Ceja v. Rudolph & Sletten, Inc.

California Court of Appeal
194 Cal. App. 4th 584, 125 Cal. Rptr. 3d 98 (2011)

  • Written by Liz Nakamura, JD

Facts

Robert Ceja started dating Nancy Ceja (plaintiff) in 2001. At the time, Nancy knew that Robert was in the process of divorcing his first wife, Christine Ceja, but Robert refused to discuss it. In September 2003, Robert and Nancy obtained a marriage license; on the license, Robert claimed he had never been married. Shortly after, Robert and Nancy were married in a large religious ceremony. Robert and Christine’s divorce was finalized in December 2003. Nancy forwarded the divorce decree to Robert’s union as part of health-insurance paperwork but did not read it carefully before submission. Robert was killed in a work accident in 2007. After Robert’s death, Nancy discovered that her marriage to Robert took place while he was still married to Christine, meaning that it was invalid as bigamous. Nancy filed a wrongful-death action against Robert’s employer, Rudolph & Sletten, Inc. (R&S) (defendant), and claimed standing as Robert’s putative spouse, arguing that she honestly believed her marriage to Robert was valid. R&S countered, arguing that Nancy did not qualify as Robert’s putative spouse because her belief in the validity of their marriage was objectively unreasonable under the circumstances. The trial court agreed and granted R&S summary judgment. Nancy appealed.

Rule of Law

Issue

Holding and Reasoning (Rushing, J.)

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