Lester v. Lester
87 N.Y.S.2d 517, 195 Misc. 1034, 1949 N.Y. Misc. LEXIS 1954 (1949)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A legally valid marriage cannot be rendered null and void by a private agreement between the parties declaring the marriage to be a sham, as such an agreement is unenforceable as a matter of public policy.
Facts:
- I. B. (petitioner) and I. A. L. (respondent) were in a relationship prior to their marriage.
- To re-establish herself in the good graces of her relatives, I. B. desired to give the impression that she and I. A. L. were married.
- Before the wedding, I. A. L. drafted and had I. B. sign a document stating the marriage was 'pretended and spurious,' entered into against his wishes due to her 'serious and dire threats,' and involved no spousal obligations.
- The parties went through a legal marriage ceremony in Elkton, Maryland.
- Immediately following the ceremony, both parties signed a second document declaring their marriage 'null and void in all its parts and implications whatsoever, ab initia.'
- Despite these agreements, the parties lived together and maintained a marital relationship, including sexual relations, for approximately ten years.
- I. A. L., a college teacher of family relations law, eventually left I. B.
Procedural Posture:
- The petitioner, I. B., initiated a proceeding in the Domestic Relations Court of the City of New York seeking an order for support from the respondent, I. A. L.
- The respondent contested the petition, asserting that no valid marriage existed due to a private agreement and alleged coercion, and therefore he had no duty of support.
- The Domestic Relations Court held a hearing to inquire into and pass upon the validity of the marriage for the incidental purpose of determining whether to issue a support order.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a private agreement between parties, stating their legally performed marriage is null and void and was entered into under duress, invalidate the marriage and its associated obligations, such as the duty of support?
Opinions:
Majority - Panken, J.
No, a private agreement does not invalidate a legally performed marriage. Although marriage is a civil contract, it is also a fundamental social institution in which the state has a strong interest, and its validity cannot be negated by the parties' private arrangements. The court found that agreements seeking to nullify a marriage are unenforceable as they violate public policy, which seeks to preserve the family institution. The respondent’s claim of coercion and duress was deemed not credible, particularly because he, a teacher of family law, cohabited with the petitioner and maintained intimate relations for ten years after the ceremony. The court reasoned that such prolonged conduct fundamentally undermines any claim of being forced into the relationship. Therefore, the marriage is valid until a court with proper equity jurisdiction declares otherwise, and the respondent is subject to the legal obligations of a husband, including the duty of support.
Analysis:
This decision reinforces the legal principle that marriage is a public institution and legal status, not merely a private contract that can be customized or nullified at will by the parties. It establishes that private agreements purporting to invalidate a legally sound marriage from its inception are void as against public policy. The ruling signals to future litigants that courts will be highly skeptical of claims of duress or coercion used to invalidate a marriage when the parties' subsequent conduct, such as long-term cohabitation, contradicts such claims. This case solidifies the state's interest in regulating and upholding the marital relationship and its attendant obligations.
