## Facts

- Michael David Estridge, Sr. and Lana Ann Taylor were firefighters/paramedics who met in 2011 while working at the same fire station.
- In 2015, Estridge was diagnosed with cancer.
- In 2016, Estridge and Taylor began dating; in 2017, their relationship became sexual.
- In early 2018, Estridge proposed to Taylor, and she accepted, but no wedding date was set.
- Because Estridge was much older than Taylor, they decided not to tell their families about the relationship; friends and coworkers knew.
- By May 1, 2019, a Chicago hospital informed Estridge that his cancer could not be stopped and that home palliative care was his best option.
- Estridge was discharged with prescribed pain medication; his palliative-care physician recorded that Estridge was alert and able to make complicated decisions.
- Taylor and two firefighter friends traveled with Estridge from Chicago to Indianapolis; during the trip, Estridge talked and laughed and said he wanted to marry Taylor.
- The couple completed paperwork for a marriage license and also executed documents designating Taylor as beneficiary of Estridge’s firefighter pension.
- On May 2, 2019, around 4:30 p.m., Estridge and Taylor married in front of firefighter friends, with the fire chief officiating.
- The next day, Estridge signed a Medicaid form electing hospice care; with his children’s consent, the form noted he was “alert to self.”
- Estridge died on May 6, 2019.
- Estridge’s estate petitioned to annul the marriage, alleging Estridge lacked mental capacity to marry due to illness and pain medication.
- At trial, the estate’s expert (Dr. McCoy) testified he lacked enough information to determine whether the medications rendered Estridge incompetent at the time of the marriage.
- Taylor’s expert (Dr. Rodgers), after reviewing medical records and deposition testimony, opined the medications did not render Estridge incompetent.
- The trial court denied the annulment petition, and the estate appealed.

## Issues

1. Whether the trial court clearly erred by finding Estridge had sufficient mental capacity to enter into a valid marriage on May 2, 2019, despite terminal illness and prescribed pain medication.
2. Whether the estate’s evidence required annulment on the theory that Estridge could not understand the nature of marriage and the legal rights and duties that come with it.

## Decision

- The Court of Appeals of Indiana affirmed the judgment denying the estate’s petition to annul the marriage.
- The court held the estate failed to show clear error in the trial court’s finding that Estridge was competent at the time of the wedding.
- The court relied on contemporaneous medical notes describing Estridge as alert and able to make complicated decisions, along with lay testimony that he interacted normally, expressed a desire to marry, and participated in related paperwork and planning.
- The court treated the estate’s argument as a request to reweigh evidence and reassess witness credibility, which is not permitted on appeal.
- The court noted the trial court was entitled to credit Taylor’s expert opinion and the lay witnesses over the estate expert’s inability to reach a definite conclusion about incapacity.

## Legal Principles

- A marriage may be annulled for lack of mental capacity only if the challenger proves the person could not understand the nature of the marriage contract and the rights and responsibilities it creates at the time of the ceremony.
- Mental capacity is a fact question; appellate review is highly deferential, and a judgment will be affirmed if supported by evidence of probative value.
- Serious illness, proximity to death, and use of prescribed pain medication do not by themselves establish incapacity; courts consider contemporaneous medical observations and the person’s conduct and decision-making.
- Trial courts may weigh and choose between competing expert testimony and lay testimony; an appellate court will not second-guess those credibility determinations.
- A challenger’s suspicions about timing, secrecy, age differences, or financial consequences do not substitute for proof of incapacity at the moment of marriage.

## Conclusion

The court upheld the marriage because the record supported the trial court’s finding that Estridge remained mentally capable of marrying Taylor on May 2, 2019, as shown by medical notes describing him as alert, witness accounts of coherent interaction and expressed intent to marry, and his completion of marriage and beneficiary paperwork shortly before the ceremony.


Estate of Estridge v. Taylor, 187 N.E.3d 275 (2022)