Knott v. Barnhart

269 F. Supp. 2d 1228 (2003)

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Knott v. Barnhart

United States District Court for the Eastern District of California
269 F. Supp. 2d 1228 (2003)

  • Written by Liz Nakamura, JD

Facts

Claudette Knott (plaintiff) married Langston Knott, a California resident, without knowing that Langston was still validly married to someone else. Claudette and Langston were married for 22 years and had four children before Claudette learned their marriage was bigamous. Under California law, Claudette then sought, and was awarded, an annulment. After Langston started receiving social security benefits, Claudette applied for a divorced spouse’s share of Langston’s benefits but was denied. At a review hearing before the administrative-law judge (ALJ), Claudette argued that she was entitled to divorced spouse benefits because she was (1) a putative spouse under California law; and (2) a deemed-valid spouse under federal law. The ALJ affirmed the denial of benefits because Claudette’s marriage to Langston was void under California law. The ALJ’s denial became the final decision of the Commissioner of Social Security (defendant). Claudette appealed.

Rule of Law

Issue

Holding and Reasoning (Moulds, J.)

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