Gormley v. Robertson

Court of Appeals of Washington
83 P.3d 1042 (2004)

ELI5:

Rule of Law:

The meretricious relationship doctrine, which provides for a just and equitable division of property acquired during a stable, marriage-like relationship, applies to same-sex couples. The legal inability of the parties to marry is not a barrier to applying this equitable doctrine.

Facts:

From July 1988 to August 1998, Lynn Gormley and Julia Robertson, two women, lived together in an intimate domestic relationship.
Both parties pooled their financial resources into a joint bank account which was used to pay for all monthly obligations.
In 1992, the couple jointly borrowed $20,000 from Gormley's father to consolidate their debts, including a pre-relationship debt belonging to Robertson.
In 1993, the couple purchased a home that was titled solely in Robertson's name for financing purposes.
Mortgage payments for the home were made from the couple's joint bank account.
The couple used joint funds to improve, decorate, and furnish the home they shared.
When the relationship ended in 1998, a dispute arose over the division of property acquired during their 10 years together.

Procedural Posture:

Lynn Gormley sued Julia Robertson in trial court seeking equitable property division.
The trial court initially granted summary judgment for Robertson, dismissing Gormley's claims based on the meretricious relationship doctrine, citing then-existing precedent.
After the Washington Supreme Court vacated that precedent in another case, the trial court reconsidered its ruling and determined the meretricious relationship doctrine was applicable.
Following a trial, the court found a meretricious relationship existed and entered a judgment in favor of Gormley, dividing the property and awarding her $32,342.50.
The trial court denied Robertson's motion for reconsideration.
Robertson (Appellant) appealed the trial court's judgment to the Court of Appeals of Washington.

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Issue:

Does the meretricious relationship doctrine, created to equitably divide property for unmarried cohabitating partners upon separation, apply to a same-sex couple?

Opinions:

Majority - Kato, J.

The meretricious relationship doctrine applies to same-sex couples. The court's reasoning is that the factors for determining a meretricious relationship—continuous cohabitation, duration, purpose, pooling of resources, and intent of the parties—are all present in this case. The court rejected the argument that the doctrine is 'quasi-marital' and therefore only applicable to couples who can legally marry. In fact, a key element of the doctrine is the parties' knowledge that a lawful marriage does not exist between them. The doctrine is a judicial remedy created to prevent unjust enrichment and ensure an equitable distribution of property upon the dissolution of a stable, marriage-like relationship, and its application should not depend on the gender of the partners.

Concurring - Brown, C.J.

While agreeing with the result of equitable property division, this opinion argues that the meretricious relationship doctrine should not be extended to same-sex couples as that is a policy decision for the legislature, not the courts, especially since Washington law defines marriage as between a man and a woman. However, the trial court's decision can be affirmed based on its inherent equitable power to resolve civil property disputes. The focus should be on the specific equities between the parties to prevent unjust enrichment, which does not require applying the meretricious relationship label. Equitable claims are not dependent on the 'legality' of a relationship or the sexual orientation of the parties.

Analysis:

This decision was a significant development in Washington family law prior to the legalization of same-sex marriage, extending property rights to same-sex couples upon the dissolution of their relationship. By focusing on the functional aspects of the relationship (e.g., pooling resources, cohabitation) rather than the legal status of the partners, the court established a precedent for preventing unjust enrichment in non-marital relationships regardless of gender. This ruling broadened the application of a judicially created doctrine to reflect the reality of modern relationships and provided a legal framework for resolving property disputes for same-sex couples on par with unmarried heterosexual couples.

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