Hill v. Durrett, 2022-NCCOA-460.
Facts: Plaintiff and Defendant were married in a friend’s backyard in 2015, and just 14 months later the couple separated. The backyard ceremony was officiated by a Ms. Plante, who was a Reiki master known as Azera Moonhawk. Ms. Plante was Defendant’s friend and was a minister of the Universal Life Church but was not authorized to perform weddings. Plaintiff eventually filed a divorce and equitable distribution action. Plaintiff also sought to have the marriage annulled based on Ms. Plante’s insufficient ordination. Plaintiff did not survive the proceedings and died before they were concluded; his estate carried on with the annulment. Defendant was the one who arranged the entire backyard extravaganza. She was the one who was good friends with Plante/Moonhawk. She was the one who told Plaintiff that Plante was qualified to perform the ceremony. She was the one who confirmed with Plante whether she could perform the ceremony. The trial court annulled. Defendant appealed.
Issue: Was the Plaintiff (his estate) equitably estopped from seeking an annulment?
Rationale: Equitable estoppel typically requires relying on some statement that amounts to a detriment. In cases where the validity of marriage is at issue, the Court has previously held that a party has some culpability in obtaining that marriage. In one case, equitable estoppel was utilized to halt a husband’s denial of a valid marriage when it was he who participated in the procurement of his wife’s invalid prior divorce. In a case similar to this one, the use of a medicine man who was ordained by the Universal Life Church did not result in estoppel when both parties relied on the medicine man’s credentials. Plaintiff in this case was hands-off in the marriage planning. It was Defendant who knew Plante, asked Plante if she could officiate, and told Plaintiff that Plante could. Since Defendant lacked culpable negligence, he could challenge the validity of his marriage.
Lessons: Did being hands-off in wedding planning truly save Plaintiff’s case? It seems that way. Since he did not take any active role in finding an officiant and relied on the representations of his wife-to-be on whether Plante was authorized, he was not culpable in the “getting married” part of marriage. Since Plaintiff had passed, his attorney testified to many out of court conversations between him and Plaintiff. Some of those were relied on to come to the conclusion not to apply estoppel, namely that Plaintiff was frustrated that he did not get married in his church, but rather the backyard; and that he did not recall who Plante was and whether she was properly ordained. If Defendant did not admit that she took the driver’s seat in wedding planning and finding an officiant, then could the Court rely on those statements for their estoppel analysis? If you believe to have an issue with invalid marriage or are seeking advice about annulments, please contact a family law specialist.