## Facts

- Anya Ponorovskaya and Wylie Stecklow began a relationship in 2004 and planned a destination wedding in Mexico.
- In 2009, they held a beach-resort ceremony in Tulum, Mexico, conducted by Stecklow’s cousin, a New York dentist ordained online as a Universal Life Church minister for the purpose of officiating weddings.
- The parties did not obtain a Mexican marriage license or complete Mexico’s civil marriage requirements, despite having information about those requirements and indicating the ceremony would be symbolic.
- After returning to New York, the parties also did not obtain a New York marriage license.
- In 2013, Ponorovskaya filed for divorce in New York and sought financial relief; Stecklow moved to dismiss, asserting there was no valid marriage.

## Issues

1. Whether New York Domestic Relations Law § 25 can validate a marriage ceremony performed outside New York when the marriage is invalid under the law of the place of celebration due to failure to obtain a license and comply with local civil requirements.
2. Whether, consistent with lex loci celebrationis and comity principles, New York should treat the parties as married despite deliberate noncompliance with the foreign jurisdiction’s marriage formalities.
3. Whether the Universal Life Church–ordained officiant was authorized to solemnize a marriage under Domestic Relations Law § 11 (raised but not decided).

## Decision

- The court granted the defendant’s motion to dismiss for failure to state a cause of action (CPLR 3211(a)(7)).
- The court held that DRL § 25 does not generally validate an out-of-state marriage that is invalid under the law of the place where it was celebrated, except possibly in extraordinary circumstances not present here.
- Because the ceremony was invalid under Mexican law and no New York license was obtained, the court found no valid marriage existed for New York to dissolve.
- The court did not reach whether the officiant satisfied DRL § 11 because the lack of a valid marriage was dispositive.

## Legal Principles

- Under lex loci celebrationis, the validity of a marriage is generally determined by the law of the jurisdiction where the marriage is celebrated; New York typically recognizes marriages valid where celebrated, subject to narrow public-policy exceptions.
- Domestic Relations Law § 25’s license-forgiving rule is construed narrowly and is not a general mechanism to cure an out-of-state ceremony that the place of celebration treats as void.
- A party seeking divorce must plead a legally cognizable marriage; absent a valid marriage, the complaint fails to state a cause of action for divorce.

## Conclusion

The court dismissed the divorce action because the parties’ Mexico ceremony was void under Mexican law and DRL § 25 did not supply a broad New York-based cure for deliberate noncompliance with foreign marriage requirements, leaving no marriage for the court to dissolve.


Ponorovskaya v. Stecklow, 987 N.Y.S.2d 543 (N.Y. Sup. Ct. 2014)