Christina M. Aldrich v. Jonathan E. Aldrich

Citation: Not availableDocket: WD84127

Court: Missouri Court of Appeals; November 2, 2021; Missouri; State Appellate Court

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Equitable estoppel can prevent a party from denying a marital relationship's validity, even if the marriage itself is not legally recognized. Jonathan E. Aldrich appeals the Circuit Court of Johnson County's dissolution judgment regarding his marriage to Christina M. Aldrich. The couple held a formal wedding ceremony in 1991, believing they were lawfully married, although Aldrich never filed the necessary marriage documentation. They lived together for 27 years, owned property as husband and wife, and had three children. Christina discovered Aldrich's infidelity in 2017, leading to their separation in 2018. Christina filed for dissolution in 2019, and for the first time, Aldrich claimed there was no valid marriage due to the absence of a marriage license. The trial court invoked equitable estoppel, ruling Aldrich could not deny the marriage's validity, and issued a dissolution judgment in June 2020, which included property division and maintenance for Christina. Aldrich's appeal challenges the trial court's authority to dissolve what he claims is an "invalid" marriage.

Aldrich's appeal centers on the existence of a valid marriage with Christina. The trial court concluded that, despite any claim of invalidity, Aldrich was estopped from denying the marriage's validity due to his long-term cohabitation, children, benefits enjoyed over 27 years, and consistent representation of their marital status to others. The court's ruling is affirmed under the standard of review, which maintains the trial court's judgment unless lacking substantial evidence, being against the weight of the evidence, or erring in law.

Missouri law has prohibited common-law marriages since 1921, requiring a marriage license and solemnization. A presumption of ceremonial marriage exists if there is evidence of open cohabitation and public declaration, even without a marriage license. In this case, Aldrich and Christina had a wedding ceremony, cohabited for 27 years, obtained property together, filed taxes as a married couple, and celebrated anniversaries, indicating a strong presumption of marriage. However, it is agreed that they did not acquire a marriage license before or during their relationship. Missouri law mandates that a marriage license is necessary for validity, and the absence of one is deemed a fatal flaw, contrary to states where licensing may be considered directory.

Failure to obtain a marriage license under Missouri law (subsection 451.040.1) invalidates the establishment of a legal marriage, which forms the basis of Aldrich’s claim. He argues that since Missouri does not recognize common-law marriage and no license was issued, his relationship with Christina was never a valid marriage. Consequently, he contends the trial court erred in dissolving a non-existent marriage, distributing non-marital property, and awarding maintenance to Christina.

However, Aldrich’s arguments are undermined by the principle of equitable estoppel. This principle requires three elements: an inconsistency in the party's prior statements or actions, reliance by the other party on those statements or actions, and resultant injury if the first party is allowed to contradict their prior stance. In marriage cases, a spouse cannot claim the invalidity of a marriage if that claim would disadvantage a party who acted in good faith, believing in the marriage's validity.

Case law supports this, indicating that actions consistent with a marital relationship (such as cohabitation and raising children) and the failure to disavow the marriage until dissolution proceedings are initiated prevent a party from contesting the marriage's validity. The doctrine of equitable estoppel ensures that parties cannot escape the responsibilities of marriage after benefitting from the relationship, thus upholding societal welfare and legal integrity.

The trial court's decision to not dismiss the petition and cross-petition was upheld, affirming its jurisdiction over the parties' relationship. Aldrich's assertion that he was never married to Christina was dismissed, as he did not contest the marriage's validity prior to litigation. For 27 years, Aldrich presented himself as married, benefitting from marital privileges including joint property ownership and tax deductions. Christina, believing herself legally married, made significant life decisions based on that belief, such as changing her surname and forgoing full-time employment. The court noted that had she not believed in the marriage's validity, she would not have made various representations on tax filings or chosen to cohabit or have children with Aldrich. Aldrich's claim to disavow the marriage, now that it serves his interests, could lead to severe consequences for Christina and their children, including loss of maintenance and implications of illegitimacy. The court applied the principle of equitable estoppel, preventing Aldrich from denying the marriage's validity based on the established facts. Consequently, all of Aldrich’s appeals, which hinge on the invalidity of the marriage, were rejected. The trial court's judgment regarding the dissolution of marriage and related matters was affirmed.