Estate of Estridge v. Taylor
Indiana Court of Appeals
187 N.E.3d 275 (2022)
- Written by Tammy Boggs, JD
Facts
Michael Estridge and Lana Taylor (defendant) were both firefighters and paramedics who met in 2011 while they worked at the same fire station. In 2015, Estridge was diagnosed with cancer. In 2016, the couple began dating, and in 2017 the relationship became sexual. In early 2018, Estridge proposed marriage, and Taylor accepted. No wedding date was set. The couple decided not to tell their families because Estridge was much older than Taylor, but their friends and coworkers knew. Meanwhile, despite Estridge’s cancer treatments, the cancer reached a terminal stage. By May 1, 2019, Estridge had been informed by a Chicago hospital that the cancer could not be stopped and that his best option was home palliative care. Estridge was discharged with prescribed pain medication to keep his pain level under control; his palliative-care physician observed that Estridge was alert and able to make complicated decisions. Taylor and two firefighter friends rode with Estridge to Indianapolis. Along the way, Estridge said he wanted to marry Taylor. Estridge talked and laughed with his friends. The couple signed appropriate documents for a marriage license and to designate Taylor as Estridge’s beneficiary for his firefighter’s pension. On May 2, 2019, around 4:30 p.m., Taylor and Estridge married in front of a group of firefighter friends. The firefighter chief presided over the ceremony. The day after the ceremony, Estridge signed a Medicaid form electing hospice; on the form, it was noted with the consent of Estridge’s children that Estridge was “alert to self.” On May 6, 2019, Estridge died. Thereafter, Estridge’s estate (the estate) (plaintiff) filed a petition to annul the marriage based on Estridge’s alleged incompetency to enter the marriage. At trial, the estate’s expert, Dr. McCoy, opined that he did not have sufficient information to assess whether Estridge’s pain medication had rendered him incompetent. Taylor and two firefighter friends testified regarding Estridge’s interactions with them and others during the ride to Indianapolis and during the marriage ceremony. Taylor’s expert, Dr. Rodgers, had reviewed the lay deposition testimony and Estridge’s medical records and opined that Estridge’s pain medication had not rendered him incompetent. The trial court denied the petition to annul the marriage, and the estate appealed.
Rule of Law
Issue
Holding and Reasoning (Riley, J.)
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