Brooklyn judge rules that marriage is valid in spite of religious annulment

April 8, 2024 Robert Abruzzese, Courthouse Editor

Hon. Nancy Sunshine and Hon. Jeffrey Sunshine at Bay Ridge Lawyers annual holiday party.

Hon. Nancy Sunshine and Hon. Jeffrey Sunshine. Brooklyn Eagle Photo Mario Belluomo

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On March 20, the Kings County Supreme Court, with Justice Jeffrey Sunshine presiding, issued a decision in a case involving a couple who got a religious marriage and annulment without ever getting a traditional marriage license.

The husband, the defendant who was identified as R.I. in the case, had the marriage annulled years after the wedding, claiming that T.I., the plaintiff and wife, had hidden her mental health history from him and questioned the legitimacy of the officiant at their wedding.

This legal maneuver by R.I. centered on two primary allegations. Firstly, he asserted that his wife had concealed her mental health history from him prior to their marriage. This claim of concealment was crucial to R.I.’s argument, as he suggested that had he been aware of T.I.’s mental health issues, he might not have entered into the marriage. Essentially, R.I. argued that this alleged nondisclosure of vital personal health information invalidated the couple’s mutual consent to marry, which is a foundational requirement for any marriage under New York law.

The husband had also raised doubts about the legitimacy of the officiant who performed their wedding ceremony. He contended that the clergy member who had solemnized their marriage might not have been authorized to do so. However, Justice Sunshine highlighted that the core issue was whether the State of New York recognizes the marriage under the Domestic Relations Law, regardless of the officiant’s standing within a religious community.

Another key point was whether a father who agreed to findings from a child protection case could stop the mother, T.I., from seeking a protection order for herself and their child in this divorce case.

Justice Sunshine decided that the marriage was indeed valid under New York law, focusing on the state’s strong policy of supporting marriage validity, especially when a child is involved. This decision was made despite the religious annulment, emphasizing that civil law, not religious decisions, determines the validity of a marriage in New York.

Justice Sunshine emphasized that the validity of the marriage, from a legal standpoint, does not hinge on the religious or ecclesiastical authority of the officiant but rather on the mutual consent of the parties to marry and the presence of a ceremony that aligns with their intentions and beliefs. He pointed out that both parties had believed themselves to be married under the laws of New York State and had lived as such.

Justice Sunshine pointed out that New York law does not condition the validity of a marriage on the full disclosure of personal health information between spouses prior to marriage. While such disclosures might be significant within the context of the couple’s personal and religious understanding of marriage, they do not bear directly on the legal validity of the marriage under state law.

This case was not the couple’s first time in court over their marriage. R.I. had previously filed for divorce in 2015, leading to a lengthy and bitter legal battle that ended in 2018 without a final divorce, after which the couple attempted to reconcile. However, T.I. initiated this new divorce case, bringing up these significant legal and constitutional issues about marriage and its recognition by the state.

Justice Sunshine’s ruling underscored that New York’s Supreme Court has the authority to decide on divorce actions regardless of any religious court’s decisions about the marriage. This ensures that civil law principles are the main criteria for determining a marriage’s validity, allowing the divorce proceedings to move forward.