California Codes

Cal. Family Code § 2091 (2026)

✓ current as of May 2026

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A divorce obtained in another jurisdiction shall be of no force or effect in this state if both parties to the marriage were domiciled in this state at the time the proceeding for the divorce was commenced.

Notes of Decisions

Cited in 3 cases (1 in the last 5 years), 2014–2023 · leading case: Woul Park v. William P. Barr, 946 F.3d 1096 (9th Cir. 2020).

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Woul Park v. William P. Barr, 946 F.3d 1096 (9th Cir. 2020). · cites it 3× “” Cal. Fam. Code § 2091 . USCIS and the district court found that Park and Choi were both California domiciliaries at the time they obtained their Korean divorce, meaning that their divorce was of “no force or effect” in California.”

In Re the Marriage of Rendon Quijada & Pimienta Dominguez, 532 P.3d 1165 (Ariz. Ct. App. 2023). “(citing Cal. Fam. Code § 2091 ). USCIS had concluded that the Korean divorce was invalid in California because the applicant and her first husband were domiciled in California when the divorce decree was executed.”

Marriage of Phillips CA4/1 (Cal. Ct. App. 2014). “Accordingly, Luzviminda asserts both parties were domiciled in California and the Guamanian judgment of divorce is void under Family Code section 2091. (Undesignated statutory references are to the Family Code.”

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