In re Dandridge

Aldo Dandridge (plaintiff) had Parkinson’s disease and dementia. Mae Ann G.-D. (defendant) was Dandridge’s live-in caregiver. Dandridge could not cook for himself, had only a limited ability to walk or dress himself, and did not always understand that he needed help. A hospital that treated Dandridge believed that he had become incapacitated and petitioned to have a court appoint a guardian to manage Dandridge’s personal and property matters. The trial court appointed a temporary guardian (plaintiff) for Dandridge. Mae Ann then transported Dandridge out of state and married him. The marriage took two ceremonies because Dandridge was not feeling well enough to complete the first one. Dandridge’s guardian approached the court with concerns about Dandridge’s capacity to agree to a marriage. The court appointed a psychiatrist to evaluate Dandridge’s mental capacity. The court also heard evidence about Dandridge’s mental state from Dandridge himself, the guardian, Dandridge’s relatives, and Mae Ann. Dandridge testified that he did not remember marrying Mae Ann and did not want to be married to her. The guardian testified that Dandridge exhibited signs of dementia, such as not understanding that he was being evicted from his apartment. The trial court found that Dandridge was legally incapacitated and, therefore, could not have legally consented to the marriage. The trial court then annulled the marriage. Mae Ann appealed the annulment.