## Facts

- Mark Porter’s 16-year-old daughter, D.P., married Ralph Rodriguez, a 34-year-old from Mississippi.
- Porter provided written parental consent for the marriage, believing Rodriguez was younger and knowing him only slightly.
- The marriage complied on its face with Arkansas marriage laws permitting a minor to marry with parental consent.
- In juvenile dependency–neglect proceedings involving Porter’s family, the state child-welfare agency treated Porter’s consent to the marriage as part of its neglect case.
- D.P.’s attorney ad litem moved within the juvenile case to have the marriage declared void, asserting that the consent was given without adequate regard for D.P.’s health and safety and without knowledge of Rodriguez’s true age.
- The trial court found Porter responsible for neglect and declared the marriage void based on (1) misrepresentation of Rodriguez’s age, (2) D.P.’s best interests, and (3) D.P.’s alleged mental incapacity, relying heavily on D.P.’s disruptive behavior during the hearing rather than her capacity when she married.

## Issues

1. Whether a court may void a minor’s marriage for mental incapacity based primarily on the minor’s behavior during later judicial proceedings rather than evidence of capacity at the time of the marriage.
2. Whether “best interests” concerns and alleged misrepresentation about an adult spouse’s age, without a statutory defect in the marriage, authorize voiding an otherwise lawful marriage in a juvenile dependency–neglect case.

## Decision

- The Arkansas Supreme Court reversed the trial court’s determination voiding the marriage on mental-incapacity grounds.
- The court held the relevant inquiry for mental incapacity is the party’s capacity at the time the marriage was contracted, not later courtroom demeanor.
- The court rejected using juvenile-court best-interests reasoning as a substitute for the statutory requirements governing when a marriage may be declared void.

## Legal Principles

- Mental incapacity to marry must be assessed at the time the parties entered the marriage; later conduct may be insufficient without proof tied to the time of consent.
- A court’s authority to declare a marriage void is limited to statutory defects; child-welfare “best interests” analysis does not independently supply grounds to nullify an otherwise valid marriage.
- Evidence of immaturity or disruptive behavior, without proof that the party could not understand the nature of marriage when consenting, does not meet the standard for voiding a marriage for incapacity.

## Conclusion

The court limited marriage-invalidity determinations to statutory grounds and required proof of mental incapacity at the time of contracting, holding that later courtroom behavior and generalized welfare concerns cannot, by themselves, justify voiding an otherwise lawful minor’s marriage.


Porter v. Ark. Dep’t of Health & Hum. Servs., 286 S.W.3d 686 (Ark. 2008)