Massachusetts Final Divorce Decree Estopped Denying Marriage Lawyers Attorneys

NORMAN SUNESON v. YVONNE SUNESONplaintiff appealed.
& State Board of Retirement.- Whether the trial court erred in rendering in
Appeals Court of Massachusettsfavor of the widow, that the plaintiff was
June 18, 1987, Decidedestopped from denying the marriage?
In 1971, Yvonne's then husband, Louis Bilodeau,Discussion:
told her he was going to obtain a Mexican divorce.Despite the probable invalidity of Yvonne's
Yvonne consented and signed several forms. divorce, the trial judge, relying on Poor v. Poor,
Shortly thereafter, she received through the mail381 Mass. 392 (1980), treated the case as one
a copy of a three-page document entitled "Finalwhere, balancing the equities, Paul would now be
Divorce Decree."  Prior to Paul's marriage toestopped from challenging the divorce.  Norman
Yvonne in 1977, Paul examined the Mexicanurges that Poor is inapplicable because here there
divorce papers. Both Paul and Yvonne enteredis no foreign judgment but only a fake decree.
into their marriage believing themselves free toThis Court, however, agree with the trial judge,
marry. They separated in 1980, and in 1982 Paulwho said: "As long as the parties' belief is sincere,
designated Norman plaintiff as his beneficiaryit makes little difference for purposes of estoppel,
under G. L. c. 32, § 11. After Paul's death in 1983,whether the divorce was issued by a Mexican
an investigation revealed that the Mexican courtcourt that lacked jurisdiction, or whether it was
that purportedly had issued the divorce decreeissued by an attorney doing a brisk business in
had no record of any action between Yvonne andfraudulent Mexican divorces.  This Court also
Louis Bilodeau and had no record of any divorceagrees with the judge that Norman, a stranger to
decree. It thus appears that an attorney forthe marriage, has standing only as Paul's designee
Bilodeau sent the parties a fraudulent and invalidand, as such, is to be estopped "just as Paul
Mexican decree.  Plaintiff, brother-in-law,would have been estopped."
commenced an action against defendant widowThe court affirmed the judgment in favor of the
seeking a declaration that he, as the designatedwidow.
beneficiary, was entitled to the retirementDisclaimer:
benefits of his deceased brother on the groundThese summaries are provided by the SRIS Law
that the widow's marriage to his brother wasGroup.  They represent the firm's unofficial views
invalid.  Superior court, Massachusetts, renderedof the Justices' opinions.  The original opinions
in favor of the widow on the basis that he wasshould be consulted for their authoritative content.
estopped from denying the marriage.  The