Accounts Management, Inc. v. Litchfield – Marriage License
Accounts Management, Inc. v. Litchfield, 576 N.W.2d 233 (S.D. 1998).
NATURE OF THE CASE: This was a dispute over the failure to record a marriage license.
FACTS: Litchfield (D) and her husband applied for a marriage license and were married four days later. About two years later, Mr. Litchfield suffered a heart attack while on a business trip. Mrs. Litchfield signed an Admission Consent Form as his wife and also an Authorization for Medical and or Surgical Treatment. Mr. Litchfield was in intensive care for seven days and brain was deprived of oxygen resulting in severe and irreversible brain damage.
Mrs. Litchfield obtained guardianship status and assumed responsibility for his affairs until his death from cancer in 1989. The medical bill for the heart attack was $14,170. Litchfield stopped making payments on the debt in 1994 after eight years. Accounts Management, Inc. (P), the successor in interest of the outstanding balance of the debt, brought this lawsuit to recover the remaining amount. Accounts Management was granted summary judgment and Litchfield appealed on the grounds that the marriage was invalid because it had never been recorded.
ISSUE: For a marriage to be valid must it be recorded?
RULE OF LAW: A marriage need not be recorded to be valid.
HOLDING AND DECISION: Most states do not have laws requiring that marriages be recorded. The law requires the person solemnizing the marriage to deliver the license to the register or deed but this does not require action or compliance on the part of those married. We cannot agree that the act of recording a marriage would be needed to perfect the marriage relationship. From these facts the Litchfields were married. We affirm the lower court’s ruling that Litchfield is responsible for paying her husband’s medical bills.