## Facts

- Kimberly M. Hall (mother) and Roberto R. Maal (father) planned a church wedding for March 2, 2002.
- A week before the ceremony, they did not obtain a marriage license because they had not finalized a prenuptial agreement.
- Despite knowing no license had been obtained, they proceeded with a full церemony performed by a minister before family and friends, followed by a reception.
- The parties later had two children and often held themselves out as husband and wife; a mortgage document referred to them as “husband and wife,” though they filed separate tax returns and Hall did not legally change her name.
- On March 11, 2003, they obtained a marriage license, but the marriage was never solemnized under that license and the license was not returned for recording within the required time.
- In 2006, Hall filed for dissolution; Maal denied a valid marriage and sought a paternity determination.
- The trial court ruled no valid marriage existed and entered a final judgment addressing paternity and child support; Maal later sought reimbursement for alleged child-support overpayments.

## Issues

1. Whether a valid marriage exists when parties knowingly undergo a wedding ceremony without first obtaining a marriage license and later obtain a license that is never solemnized or properly returned for recording.
2. Whether Florida law permits “substantial compliance,” good-faith, or equitable theories to validate a relationship as a marriage despite intentional noncompliance with statutory marriage formalities.
3. Whether the father was entitled to reimbursement for alleged child-support overpayments.

## Decision

- The en banc appellate court affirmed the trial court’s determination that no valid marriage existed.
- The court held that the 2002 church ceremony did not create a lawful marriage because the parties knowingly proceeded without a marriage license.
- The court held that issuance of a 2003 marriage license did not create a marriage because it was never solemnized and not properly completed for recording within statutory time limits.
- On cross-appeal, the court affirmed the denial of reimbursement for alleged child-support overpayments.

## Legal Principles

- After Florida’s abolition of common-law marriage, a legally recognized marriage requires compliance with statutory prerequisites, including obtaining a marriage license and completing a statutorily compliant solemnization.
- A ceremonial wedding and subsequent cohabitation or “holding out” as spouses do not create a marriage without statutory compliance.
- Equitable or “substantial compliance” theories do not validate a marriage where noncompliance with licensing and solemnization requirements is knowing and deliberate.
- Child-support obligations may be imposed and enforced through paternity proceedings independent of marital status, and reimbursement for alleged overpayments is not automatic.

## Conclusion

Florida law treats statutory marriage formalities as exclusive: because the parties knowingly married without a license and later failed to solemnize the license they obtained, no valid marriage existed, and the paternity and child-support judgment (including denial of reimbursement) was affirmed.


Hall v. Maal, 32 So. 3d 682 (Fla. Dist. Ct. App. 2010) (en banc)