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Judicial involvement in church matters is permitted only when the issue can be resolved by application of neutral principles of law.
Three days before their wedding, plaintiff and defendant had executed an antenuptial agreement which, by its terms, was to take effect only upon the solemnization of the marriage. Subsequently, plaintiff and defendant were married in a ceremony performed by a minister of the Universal Life Church (hereinafter ULC) in the Town of Jackson, Washington County. Five years later, plaintiff commenced the present action seeking a declaration that the marriage was void from its inception, and that the antenuptial agreement was thus unenforceable, because the officiant lacked authority under the Domestic Relations Law to solemnize the marriage. Alternatively, plaintiff sought a divorce as well as enforcement of the antenuptial agreement and equitable distribution of the parties' assets. Defendant answered, denying that the marriage was invalid and asserting a counterclaim for divorce. Defendant further contended that the plaintiff should be estopped from arguing that the marriage was void because such position was contrary to representations he made on the parties’ joint tax returns. Plaintiff moved for summary judgment on his declaratory judgment claim and defendant cross-moved for summary judgment, arguing that plaintiff had not carried his burden of proving the invalidity of the marriage and seeking a declaration that the antenuptial agreement was void on different grounds. Concluding that it was constrained by the holdings in Ranieri v Ranieri (146 AD2d 34, 539 NYS2d 382 , lv dismissed 74 NY2d 792, 543 NE2d 749, 545 NYS2d 106 ) and Ravenal v Ravenal (72 Misc 2d 100, 338 NYS2d 324 ) to find the marriage void as a matter of law, Supreme Court granted plaintiff's motion and denied defendant's cross motion. Defendant appealed.
Under the circumstances, did the plaintiff carry his burden of proving the invalidity of the marriage, thereby entitling him to summary judgment?
The court noted that under Domestic Relations Law § 11, no marriage shall be valid unless it was solemnized by, among others, a clergy member or minister of any religion. The court further noted that pursuant to the Religious Corporations Law, the terms clergy member and minister should include a person having authority from the church or synagogue to preside over and direct the spiritual affairs of the church or synagogue. In this case, the court held that plaintiff’s own submissions, which included the officiant's "Credentials of Ministry," established that the officiant was ordained a minister of the ULC in August 2000 and remained in good standing. Furthermore, documents submitted from the ULC's website state that those ordained as a minister by the ULC were authorized to perform weddings, baptisms and funerals and to otherwise conduct religious services through the ULC. According to the court, plaintiff did not present proof assailing the officiant's authority to conduct the church's spiritual affairs. While plaintiff stressed the unconventional nature of the church's method in selecting its ministers in an ostensible attempt to undermine the legitimacy of authority bestowed upon its ministers, judicial involvement was permitted only when the issue could have been resolved by application of neutral principles of law. The court concluded that it was not the role of the courts to question the church's membership requirements or the method by which it selected its ministers. Accordingly, the court reversed the decision which granted plaintiff’s motion for summary judgment.