Mayer v. Mayer

Doris Mayer (plaintiff) traveled to the Dominican Republic (Dominican) to obtain a divorce decree from Fred Crumpler so that she could marry Victor Mayer (defendant). Doris and Crumpler were both citizens of North Carolina. Doris obtained the divorce decree in the Dominican with Victor’s help to avoid North Carolina’s one-year-separation-period requirement. After Doris obtained the divorce, Doris and Victor married. However, the marriage deteriorated, and Doris filed for a divorce in North Carolina. Doris sought alimony pendente lite and attorney’s fees. In response, Victor asserted that their marriage was void because the divorce decree obtained was invalid. Doris argued (1) that the divorce decree was valid because North Carolina was obligated to recognize divorce decrees obtained in other states and should follow a similar approach for those obtained in foreign nations and (2) that the divorce decree was not violative of public policy because it was based on irreconcilable differences, which is a ground North Carolina uses to grant divorces, and other states do not require a waiting period. In the alternative, Doris argued that even if the divorce decree were invalid, Victor should be estopped from asserting that the divorce was invalid because he had helped obtain the divorce and later married her. The trial court held that the divorce was invalid and, consequently, the marriage was void. The court also found that Victor was not estopped from denying the marriage’s validity. Doris appealed.