Edmunds v. Edwards

Renne Edmunds (plaintiff), guardian of the estate of Harold Edwards, filed a petition against Harold’s wife, Inez Edwards (defendant), to annul their two-year marriage on the ground that Harold lacked the mental capacity to knowingly enter into a marriage contract. Inez denied the claim. Harold had been institutionalized for an intellectual disability in a state-run home for approximately 30 years. During that time, Harold met Inez, and the Edwardses formed a close relationship. After their release from the facility, Harold and Inez lived together with an acquaintance, and Harold secured employment as a food-service worker. Prior to their marriage, Harold and Inez were counseled by a pastor of a church. At a hearing, a psychologist testified that Harold was not competent to enter into a valid marriage, while a psychiatrist who knew Harold well testified that Harold had the mental capacity to fully understand the responsibilities associated with marriage. The trial court found that although Harold lacked a degree of mental capacity, his lack of capacity was not of such a nature as to render Harold incompetent to enter into his marriage with Inez. The court upheld the validity of the marriage and concluded that, at the time of the marriage, Harold had sufficient capacity to understand the nature of the marriage contract and the duties and responsibilities associated with that contract. Edmunds appealed.