Hill v. Bell

Thomas Sullivan, decedent, married Lavona Hill (plaintiff) in 1979. Hill and Thomas separated in 1983 but never divorced. In 1986, Thomas purportedly married Barbara Sullivan (defendant) in South Carolina. Thomas and Barbara obtained a marriage license and held a wedding ceremony. Barbara was not aware that Thomas was still married to Hill. In 1991, Thomas submitted pension forms to his employer, the National Football League (NFL), naming Barbara as his current spouse. Thomas died in 2002. Barbara then filed a claim for benefits from the Bert Bell/Pete Rozelle NFL Player Retirement Plan (the plan) (defendant). Several years later, Hill submitted her own claim for benefits, identifying herself as Thomas’s surviving spouse. The plan refused to pay Hill surviving-spouse benefits without a court order declaring her Thomas’s surviving spouse. Hill then sued the plan in Pennsylvania state court, claiming she was entitled to Thomas’s retirement benefits as his surviving spouse. The plan removed the case to federal court and joined Barbara to the action via an interpleader counterclaim. The federal district court held that (1) Barbara and Thomas’s marriage was void for bigamy because Thomas and Hill never divorced; and (2) Barbara was not entitled to Thomas’s retirement benefits because South Carolina had not adopted the putative-spouse doctrine. Barbara appealed, arguing that (a) the putative-spouse doctrine gave her the same rights as a legal spouse because she lived with Thomas under the good-faith belief that they were married; and (b) Thomas’s retirement benefits should therefore be apportioned between Barbara and Hill. The United States Court of Appeals for the Third Circuit certified a question to the South Carolina Supreme Court about whether South Carolina recognized the putative-spouse doctrine.