Commonwealth v. Case

29 Pa. D. & C.2d 405, 1962 Pa. Dist. & Cnty. Dec. LEXIS 235
CourtBucks County Court of Quarter Sessions
DecidedAugust 3, 1962
Docketno. 39
StatusPublished
Cited by2 cases

This text of 29 Pa. D. & C.2d 405 (Commonwealth v. Case) is published on Counsel Stack Legal Research, covering Bucks County Court of Quarter Sessions primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Case, 29 Pa. D. & C.2d 405, 1962 Pa. Dist. & Cnty. Dec. LEXIS 235 (Pa. Super. Ct. 1962).

Opinion

Monroe, J.,

Defendant, Russell J. Case, is being charged with violation of section 733 of The Penal Code of the Commonwealth of Pennsylvania in that he has failed to support his wife, Hellene R. Case. Defendant was formerly married to Elma Case; on February 3,1961, he secured a “Final Decree of Divorce” from her in Geneva County, Alabama. Prosecutrix was formerly married to Robert Lanning Kulp; on February 4, 1961, she secured a “Divorce Decree” from him in Covington County, Alabama. A general appearance for both spouses is noted in the decrees which are incorporated in the record. On February 17, 1961, Russell J. Case and the prosecutrix were married in Morrisville, Bucks County, Pennsylvania.

Defendant denies that the divorce decrees obtained by the parties in Alabama were valid because of the fraud committed on the courts in Alabama and, hence, contends that he is not now legally married to the prosecutrix. Both the divorce decrees contained a provision prohibiting each party thereto from remarrying except to each other for a period of 60 days.

On this phase of the case, there is no real conflict in the testimony of the prosecutrix and defendant. They had been “going together” for approximately two years prior to February, 1961. Mr. Case gave Mr. Kulp a check for $10,000 for Mr. Kulp’s share of the Kulp residence at 1911 Yardley Road, Yardley, Pennsylvania. During the last week of January or the first week in February, 1961, the exact date is uncertain, Mr. Case and Mrs. Kulp left together by car for Montgomery, Alabama, to obtain divorces from their respective spouses. They stayed in a Montgomery motel for two nights. Both Mr. Case and Mrs. Kulp went to the same Montgomery attorney recommended to Mr. Case by his company attorney. It was Mr. Case’s idea that the parties should get their divorces in Alabama. [407]*407After one visit to the attorney’s office in Montgomery, the parties left Montgomery, picked up Mrs. Kulp’s daughter in Virginia and returned to Bucks County.

Prior to the Montgomery visit, Mr. Case lived in an apartment in Morrisville, Bucks County; Mrs. Kulp lived in the 1911 Yardley Road house in Yardley, Bucks County. Prior to leaving for Montgomery and on her return therefrom, Mrs. Kulp was operating her own business in Trenton, New Jersey. Its operation was discontinued in January of 1962. Mr. Case has been continually employed by a corporation manufacturing pork meat products, in Trenton, New Jersey. Both parties testified that they had never been to Alabama prior to this trip, did not own any property in that. State, and had never established a residence there for' voting purposes.

Prom the foregoing, it is clear that the Cases perpetrated a fraud on the courts in Alabama as they were never good-faith residents in that State. It is equally clear that the full faith and credit clause bars a defendant from attacking a divorce on jurisdictional grounds in the courts of a sister State where both spouses have submitted themselves to the personal jurisdiction of the courts of the rendering State and the decree is not subject to such attack in the courts of that State: Sherrer v. Sherrer, 334 U. S. 343, 92 L. Ed. 1429 (1948); Coe v. Coe, 334 U. S. 378, 92 L. Ed. 1451 (1948). Compare Harrison v. Harrison, 183 Pa. Superior Ct. 562 (1957). Mr. Case, therefore, cannot attack the validity of his own divorce decree in this proceeding, if he could not do it in Alabama. In Alabama, a spouse may not. attack a collusive divorce where he himself participated in the collusion: Wright v. Wright, 230 Ala. 35, 159 So. 220 (1935).

' The leading case is Levine v. Levine, 262 Ala. 491, 80 So. 2d 235 (1955), in which a wife sought by direct attack to set aside a divorce obtained by her husband [408]*408several years earlier in an action in which she had appeared. The court held that the wife was estopped from asserting the invalidity of the divorce because she either participated in the fraud on the court or was negligent in failing to contest the residence issue.

Defendant asserts that even if he is estopped from attacking the validity of his own decree, he is not precluded from attacking the validity of the decree obtained by Mrs. Kulp. But third-party attack on a divorce decree in a sister State is dependent on its availability in the rendering State: Cook v. Cook, 342 U. S. 126, 96 L. Ed. 146 (1951). In Fairclough v. St. Amand, 217 Ala. 19, 114 So. 472 (1927), the Alabama Supreme Court held that one in privity with a person who, by fraudulent conduct, procures a divorce is es-topped to question its validity. The facts in that case were similar to those in the instant case in that the second husband was seeking to have his wife’s prior divorce declared invalid because of a fraud as to residence. The court held that Fairclough was the instigator of the prior suit; “His was the guilty knowledge of all the facts and the law in the premises.... His subsequent marriage to Dorothy after the divorce in Alabama and his recognition of the child by her are additional reasons or grounds for the estoppel against him as the real, active, guilty party in interest here”: Fairclough, supra, at 473, 474.

Likewise in Mussey v. Mussey, 251 Ala. 439, 37 So. 2d 921 (1948), the court held that the husband was estopped to deny the validity of a Nevada decree, where he was the principal movant in the Nevada proceedings wherein his wife was divorced from her first husband.

In the instant case, Mr. Case admits that it was his idea that he and Mrs. Kulp should go to Alabama to obtain their divorces. And on the strength of those divorces, he married her. Since Mr. Case would be estopped in Alabama from attacking the validity of [409]*409the Kulps’ divorce, he is estopped in Pennsylvania from collaterally attacking it.

Mr. Case and Mrs. Kulp were married in Pennsylvania within the 60-day prohibited period specified by their decrees. Pennsylvania follows the general rule that the validity of a marriage is determined by the law of the place where it was contracted: Commonwealth v. Custer, 145 Pa. Superior Ct. 535 (1941); Jewett v. Jewett, 196 Pz. Superior Ct. 305 (1961). This rule is applicable except where the marriage is repugnant to the public policy of the domicile of the parties, in respect to polygamy, incest or miscegenation, or is otherwise contrary to its positive laws, or is entered into in fraud or in evasion of the law of the domicile of the parties. It is abundantly clear that Pennsylvania is the domicile of the parties, the marriage occurred in Pennsylvania, and there is nothing in the laws of Pennsylvania which requires, as a matter of public policy or otherwise, a waiting period after a divorce decree.

While we have been unable to find any Pennsylvania cases analyzing the effect of the Alabama 60-day period of prohibition, the case of Van Storch v. Griffin, 71 Pa. 240 (1872), held that a New York decree of divorce which provided that the respondent would not be at liberty to marry again is inoperative in this State where the respondent has been divorced on her own libel. The decree in New York that she should not marry again could have no extra-territorial effect. See also Commonwealth v. Smith, 7 D. & C. 658.

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Related

Commonwealth v. Case
189 A.2d 756 (Superior Court of Pennsylvania, 1963)

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Bluebook (online)
29 Pa. D. & C.2d 405, 1962 Pa. Dist. & Cnty. Dec. LEXIS 235, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-case-paqtrsessbucks-1962.