Cody-Allen Zab v. Katherine Zab, 203 A.3d 1175

In 2006 Cody-Allen Zab set fire to a home to collect a drug debt; the 95-year-old occupant died. Zab pleaded guilty to first-degree murder and related arson charges and was sentenced to life imprisonment in 2008.
While serving his life sentence, Zab married Katherine Zab in April 2012; he filed for divorce in June 2013, Katherine was defaulted, and an absolute divorce was entered in December 2013.
In May 2017 Zab moved in Family Court to "expunge/seal record of marriage," arguing that under R.I. Gen. Laws § 13-6-1 persons serving life sentences are "civilly dead" and therefore lack capacity to marry.
The Family Court questioned jurisdiction but denied Zab’s motion, holding the marriage valid and refusing to seal the record.
On appeal, the Supreme Court considered whether Zab (deemed "civilly dead" by statute) had capacity to seek relief and whether § 13-6-1 rendered his marriage void.
The Supreme Court concluded Zab had no legal right to seek court relief because § 13-6-1 deems life prisoners "civilly dead," affirmed the Family Court order, and noted the Court could affirm on different grounds than the trial court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Zab had capacity to seek relief to seal his marriage record	Zab argued § 13-6-1 renders lifers "civilly dead," so the marriage was void and should be sealed	(No responsive brief filed)	Zab lacks legal capacity to litigate because § 13-6-1 deems life prisoners "civilly dead," so he could not seek relief; appeal not properly before the Court
Whether § 13-6-1 invalidates marriages entered by life prisoners	Zab contended marriages by lifers are prohibited under § 13-6-1 and therefore invalid	(No responsive brief filed)	Court observed statute extinguishes most civil rights of lifers; marriage capacity is prohibited, but Court affirmed on the ground Zab could not litigate due to being "civilly dead"

Twenty Eleven, LLC v. Botelho, 127 A.3d 897 (R.I. 2015) (standard of review for statutory interpretation)
Webster v. Perrotta, 774 A.2d 68 (R.I. 2001) (give plain statutory language its ordinary meaning)
Waterman v. Caprio, 983 A.2d 841 (R.I. 2009) (apply literal statutory interpretation when language is unambiguous)
Iselin v. Retirement Board of the Employees’ Retirement System of Rhode Island, 943 A.2d 1045 (R.I. 2008) (statutory interpretation principles)
Gallop v. Adult Correctional Institutions, 182 A.3d 1137 (R.I. 2018) (interpreting § 13-6-1 and holding lifers are prohibited from asserting civil actions)
John Marandola Plumbing & Heating Co. v. Delta Mechanical, Inc., 769 A.2d 1272 (R.I. 2001) (appellate court may affirm on grounds different from trial court)
Ogden v. Rath, 755 A.2d 795 (R.I. 2000) (same principle permitting alternative grounds for affirmance)