State v. Heflinger

4 Balt. C. Rep. 339
CourtBaltimore City Court
DecidedNovember 10, 1924
StatusPublished

This text of 4 Balt. C. Rep. 339 (State v. Heflinger) is published on Counsel Stack Legal Research, covering Baltimore City Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Heflinger, 4 Balt. C. Rep. 339 (Md. Super. Ct. 1924).

Opinion

FRANK, J.

The traverser was indicted by the Grand Jury of Baltimore City for bigamy. The basic facts as developed by the evidence taken at the trial before the court sitting without a jury were as follows:

The traverser was divorced from his first wife by decree of the Circuit Court of the City of Norfolk, Virginia, on June 22, 1920. The decree was absolute and unconditional in form and contained no restriction of any kind on the right of either party thereto to remarry, nor did it contain any reference to the Virginia statute presently to be quoted. On July 10, 1920, the traverser and Clelia L. Ramsay, both of whom were citizens and residents of Virginia, were married in due form of law in this city. Neither of them had any intention of changing his or her Virginian citizenship or residence, and shortly after their marriage in Baltimore, they returned to Virginia, where they lived together as husband and wife for a short while.

Subsequently, the traverser filed, in the Hustings Court, Part II, of the City of Richmond, a proceeding to have his marriage to Clelia L. Ramsay annulled on the ground that, inasmuch as the said marriage had taken place prior to the expiration of six months from the date of his divorce from his first wife, the second marriage was absolutely null and void and should be annulled because performed in violation of Section 5113 of the Virginia Code. This section was introduced in evidence at the trial of the instant case and reads as follows:

“Sec. 5113. Dissolution of doné of matrimony; neither party to marry for six months. On the dissolution of the bond of matrimony for any cause arising subsequent to the date of the marriage, neither party shall be permitted to marry again for six months from the date of such decree, and such bond of matrimony shall not be deemed to be dissolved as to any marriage subsequent to such decree, or in any prosecution on account thereof, until the expiration of such six months.”

The Supreme Court of Appeals of Virginia affirmed the decree of the lower court annulling the Baltimore marriage in an opinion which is reported in 130 Va. 289. The marriage was held to be void, because having been entered into within six months after the decree of June 22, 1920, it was solemnized in violation of the express terms of Section 5113 above quoted; that that section had extraterritorial effect and applied to the ceremony performed in Maryland, especially as both of the parties thereto were citizens and residents of Virginia and returned thereto shortly after the ceremony and subsequently resided in that State.

No reasonable objection can be raised to the exercise by the State of Virginia of the right to determine for herself the question of the validity or invalidity of a marriage between two of her own citizens and residents wheresoever solemnized. The question involved in the present case is whether under the circumstances detailed the marriage of July 10, 1920, in this city, rendered the traverser guilty of the crime of bigamy under the laws of Maryland. In the view I have taken of this case it becomes unnecessary to consider the question which was so ably discussed by counsel as to whether the State of Maryland is or is not bound in her own Courts to give effect to the law of Virginia as expounded in the case of Heflinger vs. Heflinger, supra, and to the decree of the Court in that case. I shall assume that the law of Virginia above quoted is not a penal statute, that it is entitled to and should be accorded extraterritorial effect in the Courts of the State of Maryland and that if the question of the validity of -the Baltimore marriage should be called into question in a Maryland civil court that marriage would be there held to toe null and void.

Was the traverser in going through the Baltimore marriage ceremony guilty of the crime of bigamy under the laws of this State?

The statute relating to the crime of bigamy was enacted as the Act of 1809, Ch. 138, Sec. 7 (November Session), and is codified as Section 20 of Article 27 (3 Bagby’s Annotated Code). For many years, this was regarded as constituting the entire statute law covering this crime, the Statute of 1 James I, Ch. II, although enforced in colonial times, was thought not to be a part of the law of Maryland, was not in-[341]*341eluded by Kilty in bis report; to the Legislature and will not be found in Alexander’s British Statutes.

In the ease of Barber vs. State, 50 Md. 161, the traverser had been charged in the indictment; with feloniously marrying another woman, his first wife being then living. The indictment was demurred to on the ground that it charged a felony, although under the provisions of the Act of 1809, supra, the crime of bigamy was not made a felony and, therefore, was only a misdemeanor. If bigamy was not; then a felony the objection to the indictment was a valid one and the demurrer would necessarily have been sustained.

Judge Alvey in delivering the unanimous opinion of the Court hold (50 Md. 168) that the statute of 1 Janies I had been in force in this State after the Revolution and at the time that Maryland became, an Independent State and was then still in force unless repealed or modified by some positive legislation of the State and that the only Act: of this State that is supposed to have effected such repeal is the Act of 1809, supra.

Judge Alvey then proceeds to use this language (page 109) the italics being furnished by me:

“But, if; must be remembered, it was not a principal object of the Act of 1809 to i>rescril>e offenses and define the elements of crime. Its great, object was, as declared upon its face, to establish a justly proportioned scale of punishments for existing crimes; and, hence, in the first, enacting clause, it was declared that the offenses therein-after mentioned * * * should be punished in the maimer following. Offenses at the common law were to be defined as that law defined them, and offenses created by previous statutes were left to their former statutory definition. except, in some few instances, where modifications were made in the nature and elements of the crime, and some acts that were not crimes were then made criminal for the first time. But in respect to the crime of bigamy or polygamy, while the Act; mentions the several acts that constitute the crime, it neither declares the offense to Ik; a misdemeanor or a felony, anil it uses no negative or restrictive terms in regard to any previous law. If it had been a felony at common law, it would have remained a felony after this act, and so, being a felony by a previous statute, which was in force at the time, it remained a felony; there being nothing in the Act of 1809, to negative the quality or grade of the crime, as declared by Stat. 1 Jac. I, ch. 11. Besides, the clause in the Act of 1809 in relation to the crime of bigamy, and now in the Code, does not embrace all the exceptions contained in the Statute of dames, relieving the parties from the consequence of a second marriage, during the life of the first wife, or husband. The 3rd, 4th imd 5th exceptions contained in the provisos, as stated by Blachstone are not referred to in the Act of 1809; and these exceptions are of essential importance in determining the guilt of the parties in eases where the facts constituting the exceptions could be shown to exist. We are of opinion, therefore, that the Statute of 1 Jac. X, ch. 13, is still in force in this State, modified by the Act: of 1809, as to the punishment, for the offense,

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Cite This Page — Counsel Stack

Bluebook (online)
4 Balt. C. Rep. 339, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-heflinger-mdcityctbalt-1924.