## Facts

- Cobert C. Blackwell, a widower, executed a 1980 will devising his real property to his first wife for life, with remainder to his siblings; the first wife later died.
- In November 1984, Blackwell and Nadine Fortenberry obtained a Mississippi marriage license in Walthall County.
- The next day they went to a motel in Jackson and attempted to find an authorized officiant; a justice court judge declined to perform the ceremony outside his office, and the judge’s wife referred them to Claude Clark.
- Clark was a Hinds County constable and an ordained minister of the Universal Life Church (ULC), holding ordination credentials obtained by mail.
- On November 10, 1984, Clark performed a marriage ceremony in the motel room and signed the marriage license.
- The couple returned to Walthall County, cohabited, and held themselves out as husband and wife.
- Blackwell died in February 1985; his will was admitted to probate and his sister was appointed executrix.
- Nadine renounced the will and claimed a widow’s allowance and spousal share; the decedent’s siblings denied she was a lawful spouse, arguing the ceremony was void because Clark lacked authority to solemnize marriages.

## Issues

1. Whether a ULC minister ordained by mail is a “spiritual leader” of a “religious body” authorized to solemnize marriages under Mississippi Code § 93-1-17.
2. If the officiant was authorized, whether the marriage was valid for purposes of asserting surviving-spouse rights in probate.

## Decision

- The Mississippi Supreme Court reversed the chancery court.
- The court held that a ULC minister is a “spiritual leader” of a “religious body” within § 93-1-17 and is empowered to solemnize marriages.
- Because Clark was legally authorized, the Blackwell–Fortenberry marriage was valid.
- The case was remanded for further proceedings treating Nadine as the lawful surviving spouse.

## Legal Principles

- Statutory terms authorizing marriage officiants, such as “spiritual leader” and “religious body,” are construed according to their text; absent legislative limits, they are not confined to traditional denominations or formal clerical training.
- Courts should avoid inquiries that require theological judgments about the legitimacy of a religion or the adequacy of its ordination practices when applying marriage-solemnization statutes.
- When parties obtain a marriage license, participate in a ceremony conducted by an officiant holding religious credentials, and the license is executed, the marriage will not be invalidated through a narrow reading of officiant authority where the statute reasonably includes the officiant’s status.

## Conclusion

The court held that a Universal Life Church minister with ordination credentials qualified as a “spiritual leader” of a “religious body” under Mississippi law, making the marriage valid and preserving the surviving spouse’s right to pursue statutory probate benefits.


In re Last Will & Testament of Blackwell, 531 So. 2d 1193 (Miss. 1988)