Edmunds v. Edwards
Supreme Court of Nebraska
287 N.W.2d 420 (Neb. 1980)
Renne Edmunds (plaintiff), guardian of Harold Edwards's estate, sought to annul Harold's two-year marriage to Inez (defendant), arguing Harold lacked the mental capacity to knowingly marry. Harold had spent about 30 years institutionalized for an intellectual disability, where he met Inez; after their release, the couple lived together, Harold held a job, and they received premarital counseling from a pastor. At the annulment hearing, a psychologist testified Harold was not competent to marry, while a psychiatrist who knew him well testified Harold fully understood marriage's responsibilities. The trial court found Harold had some diminished capacity but not enough to render him incompetent to marry, and upheld the marriage; Edmunds appealed.
Whether a marriage contract will be declared void for a party's mental incapacity only if, at the time of the marriage, there existed such a want of understanding as to render the party incapable of knowingly assenting to the marriage.