## Facts

- Harold Edwards, born in 1918, was institutionalized in 1939 as mentally retarded and remained institutionalized for about 30 years.
- While institutionalized, Harold met Inez Edwards (also a patient) and Bill Lancaster, who later lived with Harold in Omaha and continued living with Harold and Inez after their marriage.
- In 1969, Harold was placed in Omaha under a community program supporting less restrictive living arrangements, where he worked and lived in a supervised setting.
- Harold and Inez developed a close relationship, lived together with another person, and received premarital counseling from a pastor.
- Harold and Inez married on May 10, 1975.
- In 1977, Harold’s guardian, Renne Edmunds, sued to annul the marriage, alleging Harold lacked mental capacity to marry; Inez denied incapacity.
- At trial, expert testimony conflicted: one psychologist opined Harold was not competent (while conceding mild retardation does not automatically bar marriage), and another expert familiar with Harold opined he understood marital responsibilities; lay evidence reflected Harold’s work history, supervised independent living, and stated desire to marry.
- The district court found Harold was mentally retarded in a medical sense but had sufficient capacity to understand marriage and its duties, and it upheld the marriage as valid.

## Issues

1. Whether the guardian proved that, at the time of the ceremony, Harold Edwards lacked legal capacity to marry because he could not understand the nature of the marriage contract and its attendant duties.
2. Whether a diagnosis of mental retardation, without more, is sufficient to render a marriage void or voidable under Nebraska law.

## Decision

- The Nebraska Supreme Court affirmed the judgment denying annulment.
- The court held the marriage was valid because the evidence supported the trial court’s finding that Harold understood the nature of marriage and the responsibilities incident to it.
- The court applied the presumption that a marriage, once shown, is valid, placing the burden on the challenger to prove incapacity.
- The court accepted the distinction between medical descriptions of intellectual disability and the legal test for marriage capacity.
- Given conflicting evidence, the court deferred to the trial court’s credibility determinations and weighing of expert and lay testimony.

## Legal Principles

- A marriage, once established, is presumed valid; the party seeking annulment bears the burden to prove invalidity.
- Mental retardation or weakness of mind does not by itself invalidate a marriage; incapacity requires inability to understand the marriage contract and give intelligent consent at the time of marriage.
- The legal capacity inquiry centers on whether the person understood the nature of marriage and the duties and responsibilities incident to it.
- Where evidence of capacity is conflicting, appellate review gives substantial weight to the trial court’s factfinding based on witness observation and credibility assessments.

## Conclusion

The court upheld the marriage because the guardian did not overcome the presumption of validity, and the trial court’s supported finding that Harold understood marriage and its responsibilities satisfied Nebraska’s legal standard for capacity to marry.


Edmunds v. Edwards, 205 Neb. 255, 287 N.W.2d 420 (Neb. 1980)