RECOGNITION OF FOREIGN DECREE ANNULLING MARRIAGE

Authors

Abstract

Decisions considering the question of jurisdiction to annul a marriage or the recognition to be afforded to a decree of annulment rendered by a But upon questions in the law of divorce authorities are legion. American lawyers naturally tum to divorce as the means of securing relief for clients from distasteful or unbearable marital difficulties. But annulment cases are increasing in number, and the increase in some states may be expected to continue. In Di Lorenzo v. Di Lorenzo, 174 N. Y. 467, the court of appeals said that every misrepresentation of a material fact, made with the intention to induce another to enter into an agreement, and without which he would not have done so, justifies a court in vacating the agreement; and, further, that this general rule is applicable to the marriage contract. Here was a far reaching innovation, especially important in a state whose law provides for divorce for a single cause only. As might be expected, a host of interesting cases have arisen in reliance upon the Di Lorenzo doctrine. Some of them as discussed by Mr. Justice Crouch in 6 Cornell L. Q. 401. More will follow. To the intricate problems of the law of domestic relations thus presented there will be added the more baffling questions when the Conflict of Laws aspect of the cases is considered.

Recommended Citation

RECOGNITION OF FOREIGN DECREE ANNULLING MARRIAGE, 22 Mich. L. Rev. 358 (1924).
Available at: https://repository.law.umich.edu/mlr/vol22/iss4/7