News & Commentary

Judge Mathis Divorce Dismissed After 20 Months: California Law Explained

Linda Reese Mathis dismissed her divorce on April 6, 2026, ending 20 months of proceedings. Here's how California dismissals work.

By Antonio G. Jimenez, Esq.California5 min read

Linda Reese Mathis filed a request to dismiss her divorce case without prejudice on April 6, 2026, and the court entered the order on April 7, ending a 20-month divorce filed in August 2024. Under California Code of Civil Procedure § 581, a petitioner may voluntarily dismiss before trial, which reopens the marriage as a legal matter for California residents who reconcile after filing.

Key Facts

DetailInformation
What happenedLinda Reese Mathis voluntarily dismissed divorce petition
When filedDismissal request filed April 6, 2026; entered April 7, 2026
Original filingAugust 2024 (20-month proceeding)
Marriage length39 years
WhereLos Angeles County Superior Court, California
Reported reconciliationNovember 2024 (per TMZ)
Type of dismissalWithout prejudice
Governing statuteCalifornia Code of Civil Procedure § 581

According to TMZ's April 8, 2026 report, the couple reconciled roughly three months after the August 2024 filing but waited approximately 17 months to formally close the court case. Greg Mathis, 65, and Linda Reese, 64, have been married since 1987.

Why This Matters Legally

A voluntary dismissal without prejudice fully restores the legal status of the marriage in California. When Linda Reese Mathis filed her Request for Dismissal (Form CIV-110) on April 6, 2026, the court clerk's entry the next day eliminated the pending divorce petition entirely. The couple's 39-year marriage, which began in 1987, legally continues as though the August 2024 petition had never been filed.

This matters for three reasons. First, the automatic temporary restraining orders (ATROs) that took effect when the original petition was served — restricting asset transfers, insurance changes, and child relocation under Cal. Fam. Code § 2040 — are lifted. Second, the six-month statutory waiting period required under Cal. Fam. Code § 2339 resets if either spouse files again. Third, any temporary support or custody orders issued during the proceeding terminate automatically.

The "without prejudice" designation is the critical legal term here. It means either spouse can refile a new divorce petition at any time in the future without being barred by the prior case. Had Linda dismissed with prejudice, she could not refile on the same grounds — though in no-fault California, that distinction has limited practical effect because irreconcilable differences can always be newly alleged.

How California Law Handles Divorce Dismissals

California is a pure no-fault state, and Cal. Fam. Code § 2310 permits dissolution on grounds of irreconcilable differences or permanent legal incapacity only. Because fault is irrelevant, reconciliation is procedurally simple: the petitioner files Form CIV-110 (Request for Dismissal) with the court clerk, who enters the dismissal without judicial approval in most circumstances.

Under California Code of Civil Procedure § 581(b)(1), a petitioner has an absolute right to dismiss without prejudice before the defendant files an answer or any trial has commenced. After an answer is filed, dismissal generally requires either consent of the respondent or a court order. In the Mathis case, the 20-month timeline suggests substantive filings likely occurred, meaning Linda's dismissal likely required either Greg's non-opposition or judicial approval.

California spouses who reconcile have two procedural options. Option one is voluntary dismissal under § 581, which terminates the case entirely. Option two is filing a legal separation conversion under Cal. Fam. Code § 2345, though this is rarely used when parties fully reconcile. A third informal option — simply allowing the case to sit dormant — carries risk because California courts may dismiss inactive cases for failure to prosecute under Cal. Code Civ. Proc. § 583.410 after two years of inactivity.

Reconciled California couples should also consider whether to execute a post-reconciliation agreement. Under Cal. Fam. Code § 1500, spouses may contract regarding property rights during marriage. A written reconciliation agreement can clarify what happens to any property that was characterized or transferred during the proceeding.

Practical Takeaways for California Residents

  1. File Form CIV-110 promptly after reconciliation. Waiting 17 months, as the Mathises did, keeps ATROs in place and restricts normal financial decisions like refinancing a home or changing beneficiaries under Cal. Fam. Code § 2040.

  2. Choose dismissal without prejudice. This preserves the right to refile if reconciliation fails. Under Cal. Code Civ. Proc. § 581, "without prejudice" is the default for pre-judgment voluntary dismissals.

  3. Confirm both spouses agree. If a responsive pleading was filed, both parties typically must sign the dismissal or the court must approve it. Unilateral dismissal after answer is not automatic.

  4. Terminate temporary orders explicitly. Although dismissal ends temporary support and custody orders automatically, request a written order confirming termination to avoid enforcement confusion.

  5. Document any mid-proceeding transfers. Assets moved during the case may carry characterization questions. Execute a written agreement under Cal. Fam. Code § 1500 memorializing any property understandings.

  6. Understand the six-month clock resets. California's six-month waiting period under Cal. Fam. Code § 2339 restarts if either spouse later refiles. A new petition in 2027 would not be eligible for judgment until at least six months after service.

Frequently Asked Questions

Legal Disclaimer

This article discusses recent news and provides general legal commentary. It does not constitute legal advice. Every case is unique. Consult a qualified family law attorney for advice specific to your situation.

Key Questions

Can you dismiss a divorce case in California after filing?

Yes. Under California Code of Civil Procedure § 581, a petitioner may voluntarily dismiss a divorce without prejudice before the respondent files an answer. After an answer is filed, dismissal generally requires respondent consent or court approval. Form CIV-110 is filed with the clerk, who enters dismissal within days.

What does dismissed without prejudice mean in a California divorce?

Dismissed without prejudice means the case is terminated but either spouse can refile a new divorce petition in the future. Under California Code of Civil Procedure § 581, this is the default for voluntary pre-judgment dismissals. The six-month waiting period under Cal. Fam. Code § 2339 resets with any new filing.

How long do California divorce cases typically take before reconciliation?

California imposes a mandatory six-month waiting period from service under Cal. Fam. Code § 2339 before a divorce judgment can be entered. Contested cases often extend 12 to 18 months. The Mathis case lasted 20 months from the August 2024 filing to the April 7, 2026 dismissal — roughly standard for Los Angeles County.

Do automatic restraining orders end when a California divorce is dismissed?

Yes. The automatic temporary restraining orders (ATROs) under Cal. Fam. Code § 2040 — which restrict transferring assets, changing insurance beneficiaries, and relocating children — terminate automatically when the court enters a dismissal. In the Mathis case, ATROs that took effect in August 2024 ended on April 7, 2026.

Should California couples sign an agreement after reconciling and dismissing divorce?

Yes, in most cases. Under Cal. Fam. Code § 1500, spouses may contract regarding property rights during marriage. A written reconciliation agreement clarifies the characterization of any assets transferred or acquired during the proceeding and helps prevent disputes if the marriage later ends. Most California family law attorneys recommend executing one within 30 days of dismissal.

Written By

Antonio G. Jimenez, Esq.

Florida Bar No. 21022 | Covering California divorce law