Marriage of Richter v. Richter
625 N.W.2d 490, 2001 Minn. App. LEXIS 461, 2001 WL 436201 (2001)
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Rule of Law:
Marriage is not a contract within the meaning of the Contract Clauses of the United States and Minnesota Constitutions. Therefore, state statutes permitting the dissolution of a marriage do not unconstitutionally impair the obligation of contracts.
Facts:
- Kevin Richter and Barbara Richter married in 1983.
- In September 1999, Barbara Richter petitioned to dissolve the marriage.
- Kevin Richter opposed the dissolution, arguing the marriage was not irretrievably broken.
- The parties had been separated, but for a period of less than 180 days before the wife filed her petition.
- At the final dissolution hearing on May 8, 2000, Kevin Richter withdrew from the courtroom.
- Barbara Richter remained and provided uncontradicted testimony to the court about the state of the marriage.
Procedural Posture:
- Barbara Richter (wife) petitioned the Minnesota district court (trial court) to dissolve her marriage to Kevin Richter (husband).
- Kevin Richter, representing himself, filed a motion to dismiss the dissolution proceeding, arguing that the state's dissolution statutes unconstitutionally impaired his right to contract.
- The district court denied the husband's motion to dismiss.
- At the final hearing, the district court denied the husband's request for a continuance.
- The district court heard testimony from the wife and entered a judgment dissolving the marriage.
- The district court denied the husband's posttrial motion.
- Kevin Richter (appellant) appealed the judgment to the Minnesota Court of Appeals.
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Issue:
Is marriage a contract for the purposes of the Contract Clauses of the United States and Minnesota Constitutions, thus making state dissolution statutes an unconstitutional impairment of that contract?
Opinions:
Majority - Shumaker, J.
No, marriage is not a contract within the meaning of the constitutional prohibition against the impairment of contracts. The court held that while marriage is considered a civil contract for purposes of establishing its legal validity, it is not a contract in the commercial sense protected by the Contract Clause. The court relied on U.S. Supreme Court precedent, primarily Maynard v. Hill, which explicitly stated that marriage is not a contract within the meaning of the prohibition. The court also rejected the husband's reliance on dictum in Dartmouth College v. Woodward, noting that the Supreme Court itself later clarified in Maynard that the Contract Clause was never intended to restrict a state legislature's general right to legislate on the subject of divorce. Therefore, Minnesota's dissolution statutes are a constitutional exercise of state power.
Analysis:
This decision reaffirms the long-standing legal principle that marriage is a unique legal status subject to state regulation, rather than a mere private contract protected by the Contract Clause. It clarifies that state legislatures possess broad authority to define the terms under which a marriage can be dissolved, even over the objection of one party. The ruling effectively prevents parties from using the Contract Clause as a shield to block no-fault divorces, thereby upholding the modern statutory framework for marital dissolution and reinforcing the state's plenary power over domestic relations.
