Arnold v. Villarreal, No. 14-3204 (7th Cir. 2017)Annotate this Case
In 2004, Arnold and Villarreal exchanged marriage vows in California in a ceremony solemnized by a priest and a rabbi. They failed to file their marriage license with the county recorder within 10 days as required by California law. The county notified them that the license had not been filed, as necessary to complete the legal process. The couple did nothing; the license expired. Although they were not legally married, they had a child and purchased a condo in California. By 2007, their relationship had deteriorated. They filed for divorce—she in California, he in Illinois. Divorce proceedings were terminated when they stipulated that they were never married. Arnold then sued Villarreal in federal court in Chicago, claiming that she tricked him into believing they were legally married to induce him to give her gifts, including the condo. The district court entered summary judgment for Villarreal, characterizing the suit as “frivolous.” The Seventh Circuit affirmed. The undisputed facts show that Villarreal told Arnold early on that she suspected they weren’t legally married. She wanted to get a new marriage license and repeat the ceremony. Arnold knew, from the county recorder, that the marriage license had not been filed. The court awarded Villarreal sanctions against Arnold for filing a frivolous appeal.