Handley v. Handley

California Court of Appeal
179 Cal. App. 742, 179 Cal. App. 2d 742, 3 Cal. Rptr. 910 (1960)

ELI5:

Rule of Law:

A marriage can be annulled for fraud if, at the time of the marriage, one party harbors a secret intent to refuse to fulfill the fundamental duties of the marital relationship, such as cohabitation and public acknowledgment of the marriage, as this concealment defeats the essential purpose of the marriage contract.

Facts:

Raymond Handley and Mary Domokos were married on April 20, 1951.
For the entire six years of their marriage, the parties never lived together in a common residence; Handley resided in various rooming houses while Domokos Handley lived separately with her daughter.
Throughout the marriage, Domokos Handley consistently used her maiden name on all personal, professional, and financial records, including her teaching credentials, bank accounts, and the title to a house she purchased.
Domokos Handley concealed the marriage and refused to introduce Handley to her friends and acquaintances as her husband.
Handley believed the separate living arrangement was a temporary measure to allow Domokos Handley's daughter to adjust to the marriage.
Shortly after Handley separated from her on June 17, 1957, Domokos Handley began using her married name and publicly acknowledged the marriage for the first time.

Procedural Posture:

Raymond Handley (plaintiff) filed a complaint in a California trial court seeking an annulment of his marriage to Mary Domokos Handley (defendant) on the grounds of fraud.
After a hearing, the trial court found in favor of Handley and entered a judgment granting the annulment.
Mary Domokos Handley (appellant) appealed the trial court's judgment to the California District Court of Appeal.

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Issue:

Does a spouse's secret intention at the time of marriage to never cohabitate, adopt the other's name, or publicly acknowledge the marriage constitute fraud sufficient for an annulment?

Opinions:

Majority - Kaufman, P. J.

Yes. A secret intention, concealed at the time of marriage, to refuse to fulfill core aspects of the marital relationship is fraud that goes to the essence of the marriage contract and constitutes grounds for annulment. The court reasoned that fraud is sufficient for annulment if it relates to a matter vital to the marriage, defeating the essential purpose of the deceived spouse in entering the union. Citing precedent like Bruce v. Bruce, the court held that cohabitation is a fundamental aspect of the marital relationship, and a secret intent never to live with one's spouse is a fraud that strikes at the very essence of marriage. The evidence of the defendant's conduct—maintaining a separate home, consistently using her maiden name, and concealing the marriage from public view—was sufficient for the trial court to infer that she possessed this fraudulent intent from the inception of the marriage.

Analysis:

This decision clarifies that the grounds for annulment based on fraud extend beyond concealments related to procreation or sexual relations to include the fundamental social and domestic aspects of marriage. It establishes that a secret intent to reject the basic, commonly understood components of a marital partnership, such as cohabitation and holding oneself out as a married couple, can defeat the 'essential purpose' of the marriage contract. This broadens the 'essence of the marriage' doctrine, allowing courts to consider a party's entire course of conduct to determine if they entered the marriage with fraudulent intent. The case serves as a precedent for annulling marriages that are a sham in practice, even if legally valid on paper.

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