Sharon Everetts v. Kenneth S. Apfel, Commissioner, Social Security Administration
214 F.3d 990 (2000)
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Rule of Law:
Under Missouri law, which governs marital status for Social Security benefit purposes, the annulment of a voidable marriage is effective only from the date of the decree and does not retroactively validate a subsequent marriage that was bigamous when contracted.
Facts:
- In September 1953, Sharon Everetts, then fifteen, was raped by Joseph Everett.
- With her mother's consent, Everetts was forced to marry Joseph Everett in a marriage ceremony.
- The day after the marriage, Joseph Everett left and was never seen or heard from again.
- In February 1983, Everetts participated in a marriage ceremony with Mitchell Reid.
- In 1990, Mitchell Reid died.
- In March 1996, an ex parte proceeding in a Missouri state court resulted in a decree declaring Everetts's 1953 marriage to Joseph Everett 'annulled as though never in force' and 'null and void... ab initio.'
Procedural Posture:
- Sharon Everetts filed a claim for Widow's Insurance Benefits on Mitchell Reid's record with the Social Security Administration (SSA).
- An Administrative Law Judge (ALJ) denied the claim, finding Everetts did not have a valid marriage to Reid.
- The SSA Appeals Council denied Everetts's request for review, making the ALJ's decision the final decision of the Commissioner of Social Security.
- Everetts sought judicial review in the United States District Court for the Eastern District of Missouri.
- The District Court granted summary judgment in favor of the SSA.
- Everetts appealed the District Court's judgment to the U.S. Court of Appeals for the Eighth Circuit.
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Issue:
Does a state court's ex parte annulment decree, which declares a marriage void ab initio on grounds of duress, require the Social Security Administration to recognize a subsequent marriage as valid for the purpose of awarding Widow's Benefits, when state law treats marriages entered into under duress as merely voidable?
Opinions:
Majority - Arnold, J.
No. The state court's annulment decree does not require the Social Security Administration to recognize the subsequent marriage as valid because under Missouri law, the annulment of a voidable marriage does not relate back in time. The validity of a marriage for Social Security purposes is determined by the law of the state where the wage earner was domiciled, which in this case is Missouri. Missouri law distinguishes between 'void' marriages (invalid from inception) and 'voidable' marriages (valid until annulled), such as those resulting from duress. Although the annulment decree used 'void ab initio' language, the underlying ground was duress, which renders a marriage voidable. The Social Security Administration was not a party to the ex parte annulment proceeding and is therefore not bound by its specific language under collateral estoppel principles. Because the first marriage was merely voidable, the 1996 annulment did not retroactively validate the 1983 marriage to Reid, which was bigamous and thus invalid when it occurred. Therefore, Everetts does not qualify as Reid's 'widow' under the Social Security Act.
Dissenting - Heaney, J.
The majority's analysis is irrelevant because there is no evidence a marriage to Mr. Everett ever occurred. The plaintiff testified without contradiction that no marriage ceremony ever took place, which is a requirement for a valid marriage under Missouri law, in addition to a license. The record contains no evidence to rebut her testimony. Furthermore, the marriage license itself was issued on the same day as the application, contrary to the statutory three-day waiting period, and there is no court order in the record waiving this requirement. Because no valid first marriage existed, the plaintiff's marriage to Mitchell Reid was valid from its inception, and she is therefore entitled to Widow's Benefits.
Analysis:
This case illustrates the principle that federal agencies and courts will look to state law to determine domestic relations issues, such as marital status, when adjudicating claims for federal benefits. It underscores the critical legal distinction between 'void' and 'voidable' marriages, demonstrating that the legal effect of an annulment depends on this classification. The ruling also establishes that an administrative agency like the Social Security Administration is not necessarily bound by the precise language of a state court decree obtained in a non-adversarial, ex parte proceeding, particularly when that language mischaracterizes the substantive state law.
