Hill v. Bert Bell/Pete Rozelle NFL Player Retirement Plan

We certified the following question from the United States Court of Appeals for the Third Circuit:

Does South Carolina recognize the “putative spouse” or “putative marriage” doctrine (hereinafter, putative spouse doctrine)?

We answer the certified question, “no.”

I

This action involves competing claims to the retirement benefits of the late Thomas Sullivan (Thomas), former National Football League (NFL) running back for the Philadelphia Eagles.

On March 15, 1979, Thomas married Lavona Hill (Hill) in Maryland. Thomas and Hill separated in 1983, but never divorced. On March 15, 1986, Thomas…