Ceja v. Rudolph & Sletten, Inc.
56 Cal. 4th 1113
| Cal. | 2013Background
- Nancy Ceja sued Rudolph & Sletten for wrongful death as decedent's putative spouse under §377.60(b).
- Decedent Robert Ceja died in a construction-site accident on September 19, 2007; plaintiff claimed dependency as putative spouse.
- Decedent was married to Christina Ceja in 1995; by September 2003 he was separated and sought dissolution.
- Plaintiff and decedent married on September 27, 2003, three days after filing but before dissolution became final.
- Dissolution of decedent's prior marriage to Christina was not finalized until December 26, 2003; court notice warned no remarriage until termination.
- Plaintiff signed a marriage license knowing of decedent's prior marriage; she and decedent acted as spouses (name change, joint finances, living together).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standard for good faith under §377.60(b) | Good faith is purely subjective. | Good faith includes objective reasonableness. | Good faith is subjective; reasonableness is a factor in totality of circumstances. |
Key Cases Cited
- In re Marriage of Vryonis, 202 Cal.App.3d 712 (Cal. App. Dep't 1988) (criticized as adopting objective reasonableness postulates; disapproved later in Ceja)
- Vallera v. Vallera, 21 Cal.2d 681 (Cal. 1943) (good faith inquiry for putative spouses is a credibility inquiry)
- Estate of Goldberg, 203 Cal.App.2d 402 (Cal. App. 1962) (good faith assessed from surrounding circumstances)
- Miller v. Johnson, 214 Cal.App.2d 123 (Cal. App. 1963) (unreasonableness of actions negates good faith)
- Sancha v. Arnold, 114 Cal.App.2d 772 (Cal. App. 1952) (reasonableness of belief can bolster credibility in good faith)
- Coats v. Coats, 160 Cal. 671 (Cal. 1911) (prior cases on good faith and legitimacy of marriage conduct)