Ronald Bordone v. Virginia Bordone

Summary

The Pennsylvania Superior Court considered whether Pennsylvania or Connecticut law governed the validity of the parties’ marriage. The concurring opinion explains that, despite the general rule recognizing marriages valid where celebrated, Pennsylvania’s interests and its Divorce Code supported applying Pennsylvania law to validate the marriage and preclude annulment.

Holdings

1. Pennsylvania law may govern the validity of a marriage celebrated in another state when the surrounding circumstances demonstrate that Pennsylvania has the greater interest in determining the marriage's validity; the place-of-celebration rule is subject to exceptions, including conflicts with the public policy of the parties' domicile.
2. The marriage was valid under Pennsylvania law and therefore was not subject to annulment.

Questions Presented

1. Whether the law of Connecticut, where the parties celebrated their marriage, governed the marriage's validity.
2. Whether Pennsylvania law could be applied under 23 Pa.C.S. § 1702(a) to validate the marriage and preclude annulment despite an asserted impediment under the law of the place of celebration.

Disposition

other