Ponorovskaya v. Stecklow

Anya Ponorovskaya (plaintiff) and Wylie Stecklow (defendant) were residents of New York State who decided to celebrate a symbolic wedding ceremony in Quintana Roo, a state in Mexico. Ponorovskaya and Stecklow knew that the government of Quintana Roo had stringent requirements for valid wedding ceremonies; for example, the wedding officiant was required to be a member of the Quintana Roo Civil Registry. A ceremony that was not officiated by a member of the civil registry was considered an absolute nullity under the law of Quintana Roo. Ponorovskaya and Stecklow chose a symbolic wedding ceremony that did not satisfy the governmental requirements of Quintana Roo, knowing that the ceremony did not result in a valid marriage in Mexico. Upon their return to New York, Ponorovskaya and Stecklow began the application for a New York State marriage license, but they left it unfinished and unsubmitted. In 2013, Ponorovskaya filed for divorce, seeking an equitable distribution of marital property and maintenance. Ponorovskaya conceded that the marriage was an absolute nullity under the law of Quintana Roo but argued that the New York domestic-relations law (NYDRL) required New York courts to recognize the marriage as valid despite the failure to obtain a marriage license. Stecklow filed a motion to dismiss for failure to state a cause of action.