EDMUNDS V. EDWARDS 287 N.W.2d 420 (1980) CASE BRIEF

EDMUNDS V. EDWARDS

287 N.W.2d 420 (1980)

NATURE OF THE CASE: This was a dispute over mental capacity to enter into marriage. Edmunds (P) guardian, challenged an order, which found the marriage of Inez (D), the ward and the wife, valid. The trial court concluded that D had sufficient mental capacity to enter into a valid marriage contract. The issue was whether the trial court erred in assessing D as capable of entering a valid marriage.

FACTS: Harold Edwards was born in 1918 and was institutionalized at a home for the retarded in 1939. He stayed there for 30 years wherein he met Inez who was also a patient at the home. Harold eventually entered a program in which he got a job and lived in his own apartment. Harold was quite good at his job and got promotions and salary increases. Harold and Inez eventually decided to get married and were married. A guardian Edmunds (P) brought this action two years later to annul the marriage. It was determined at trial the Harold was afflicted with mild mental retardation. Experts testified that Harold was not competent to enter into a marriage but that the status of being a mild mental retard did not preclude that such a person would be incompetent to marry. Another expert for Harold testified that he had shown remarkable progress with his disabilities and that he was capable of understanding marriage and that his mental abilities had improved with age and training. Various lay witnesses were called to testify about the couples abilities to coup with married life. The trial court found Harold competent to enter into the marriage P appealed.

ISSUE:

RULE OF LAW:

HOLDING AND DECISION:

LEGAL ANALYSIS:

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