## Facts

- Boyce Duane Williams (husband) filed for divorce in Tulsa County District Court on the statutory ground of incompatibility.
- Celestia Elizabeth Williams (wife) opposed the divorce, asserting the parties’ shared religious belief that only adultery justifies divorce.
- No adultery was alleged as a basis for dissolving the marriage.
- The district court granted the husband a divorce on incompatibility.
- The wife appealed solely the authority of the court to grant a divorce on incompatibility in light of the parties’ religious vows and beliefs.

## Issues

1. Whether a civil court may grant a divorce on the statutory ground of incompatibility when the parties’ religious vows recognize only adultery as a permissible basis for divorce.

## Decision

- The Supreme Court of Oklahoma affirmed the divorce decree.
- The district court had authority to dissolve the civil marriage on incompatibility, regardless of the spouses’ religious beliefs about divorce.
- Courts lack constitutional and statutory power to interpret or enforce ecclesiastical marriage vows.
- The record supported incompatibility, and granting the divorce was not an abuse of discretion.

## Legal Principles

- Marriage may have both a civil aspect (a legal status and contract governed by state law) and an ecclesiastical aspect (religious obligations governed by faith and conscience).
- Under separation of church and state, civil courts may not adjudicate religious doctrine or compel compliance with ecclesiastical vows.
- Legislatures may establish civil grounds for divorce, including incompatibility; those grounds apply without regard to the parties’ sectarian standards.
- A spouse’s religious objection to divorce does not limit the state’s authority to dissolve the civil marriage relationship.

## Conclusion

The court held that divorce is a civil remedy controlled by state law, and a district court may grant a divorce for incompatibility even when both spouses’ religious beliefs would permit divorce only for adultery.


Williams v. Williams, 543 P.2d 1401 (Okla. 1975)