Randall v. Randall

In the summer of 1963, Feather Randall (defendant) and Robert Randall (plaintiff) began a romantic relationship. Robert obtained a divorce decree from his prior marriage on October 4, 1963. Feather and Robert were aware that under Nebraska law, Robert would have to wait to remarry until April 5, 1964. In March 1964, Feather and Robert traveled to Mexico to marry. On April 4, 1964, Feather and Robert obtained a marriage license from a local government office, which was required under Mexican law. Feather and Robert signed the marriage license and were told by a Mexican official that they were deemed married. However, after Feather and Robert informed the official that they were unable to marry under Nebraska law until April 5, the official informed them that the transaction was no longer sufficient to constitute a marriage. On April 5, Feather and Robert met with a minister to perform a marriage ceremony. Although the minister informed Feather and Robert that Mexican law required that a marriage first be performed by a Mexican civil authority, they went through with the religious marital ceremony. Feather and Robert then returned to Nebraska and continued to cohabitate as if they were married. However, the relationship deteriorated, which resulted in dissolution proceedings. The trial court questioned the validity of the marriage but held that the marriage was valid. The trial court reasoned that although the marriage was invalid under Mexican law because no valid civil proceeding had occurred, the religious ceremony that had been conducted in Mexico satisfied Nebraska’s requirements for a valid marriage. The trial court then awarded Feather spousal support and part of the marital estate. Robert appealed on the ground that the marriage was invalid. Robert argued that because the marriage occurred in Mexico and under Mexican law the marriage was invalid, there was no valid marriage.