California Appellate Court, 6th District (Santa Clara): Vryonis decision (1988) invalidating Iranian Cultural Marriage was erroneous
Santa Clara, California, April 19, 2011: In Ceja v. Rudolph & Sletten, Inc., the California Appellate Court for the 6th District held that an innocent party to an invalid marriage would be entitled to marital benefits even if her belief was unreasonable.
By this holding, the court disagreed with more than two decades of California law reflected in the case of “In re Marriage of Vryonis”, decided in 1988, which declared that good faith belief in validity of marriage must be reasonable.
In Vryonis the court rejected claim of an Iranian woman who believed her private cultural marriage to her Greek husband was valid, although it was made in her home, without obtaining a marriage license as required by California law.
In Ceja, after death of her Husband at work, Mrs. Ceja brought action for wrongful death, but Husband’s employer moved for summary judgment claiming that as a matter of law, Mrs. Ceja did not qualify as a putative spouse because at the time of marriage knew that her Husband is married.
The trial court agreed and granted summary judgment, applying an objective test for putative status. The court found that it was not objectively reasonable for Mrs. Ceja to have believed that her marriage was valid. The appellate court disagreed. The court believed that good faith belief in validity of marriage asks whether that person actually believed the marriage was valid and whether he or she held that belief honestly, genuinely, and sincerely, without collusion or fraud.
The court disagreed with In re Marriage of Vryonis, which held that the statutory language incorporates an objective test. The court found that: 1. The concept of putative spouse, allowing marital benefits to a spouse even if the marriage is defective is a judicially created relief and the judicial definition of the putative spouse required only a good faith belief in the validity of a marriage. 2. The Legislature codified that definition without intending to change it. 3. The Vryonis court engrafted an objective test to the statutory definition based on the legally unsupported view that “good faith belief” necessarily incorporates an objective standard. 4. The Vryonis court intruded upon the Legislature’s prerogative.
The courts have followed and uncritically accepted Vryonis decision but the policy of stare decisis carries little weight. Despite its widespread acceptance, Vryonis created a conflict with prior cases. The rule of statutory construction is inapplicable, because there is an unresolved conflict in the judicial holdings. https://www.courts.ca.gov/documents/5-s193493-app-nancy-ceja-answer-brief-merits-111411.pdf