Cantarella

In this case, we consider whether registration of a marriage certificate was vital to the validity of a marriage under the Family Law Act (Civ. Code, former § 4000 et seq.).

In 1991, a judge conducted a marriage ceremony for Joseph S. Cantarella (husband) and Tanya M. Cantarella (wife). The marriage certificate, however, was twice rejected for registration due to a technical error on the document. After the second rejection, the parties decided not to resubmit the certificate for registration, possibly to avoid the tax consequences of marriage. 2 As a result, the 1991 marriage was never registered. Nine to 11 years later (between 2000 and 2002), the parties were married in a new ceremony. *920 In 2008, the parties dissolved the marriage. As part of the dissolution judgment, the family court ordered husband to pay wife spousal support for several years in accordance with an agreement between the parties.

Husband subsequently sought modification of the spousal support order. At the hearing on his order to show cause, the parties disagreed about how long they had been married. Husband argued the parties were married in 2000. But wife—contrary to a filing she had made…