Mark Belliveau v. Janet Whelan

Summary

The Maine Supreme Judicial Court affirmed the dismissal of Mark Belliveau’s divorce complaint because he and Janet Whelan did not satisfy Maine’s statutory requirements for a valid marriage. The court declined to adopt either the putative spouse doctrine or marriage by estoppel, concluding that doing so would improperly intrude on the Legislature’s policy-making function and create uncertainty in Maine marriage law.

Holdings

1. Maine does not recognize common-law marriage, and the court declined to adopt either the putative spouse doctrine or the doctrine of marriage by estoppel as an end-run around Maine's statutory requirements for a valid marriage.
2. The complaint for divorce was properly dismissed because Belliveau and Whelan were never legally married under Maine law.

Questions Presented

1. Whether Maine should recognize the putative spouse doctrine to treat the parties as married despite their failure to satisfy statutory marriage requirements.
2. Whether Maine should recognize the doctrine of marriage by estoppel under the circumstances presented.
3. Whether the District Court properly dismissed the complaint for divorce because the parties were never legally married.

Disposition

affirmed