Rodenhiser v. Duenas, 296 Mich. App. 268

This is an action for annulment brought by Mullin's sisters Connie and Jeannie, personal representatives of Mullin's estate, against Rene Dueñas.
Mullin was terminally ill in 2009 and married Dueñas while hospitalized for stage-4 cancer.
Plaintiffs sought to annul the marriage on grounds Mullin lacked legal capacity to contract at the time of marriage.
A two-day bench trial was held; the trial court granted defendant's motion to dismiss for lack of clear and definite proof of incompetence.
On appeal, the court reviews de novo equity and vacates or affirms the dismissal order, affirming the trial court.
The court ultimately held that third parties lack standing to pursue fraud-based annulment and affirmed dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing to seek annulment for fraud	Rodenhiser argued Mullin was defrauded in the marriage.	Dueñas argued only a party to the marriage may seek annulment for fraud.	Third parties lack standing; action dismissed.
Whether Mullin lacked legal capacity to contract marriage	Plaintiffs asserted clear and definite proof of incompetence existed.	Defendant contends Mullin had periods of alertness and capacity; evidence insufficient for incapacity.	No clear proof Mullin had no reasonable perception of the marriage; capacity found at times.

In re Adams Estate, 362 Mich 624 (Mich. 1961) (strong presumption of valid ceremonial marriage)
Quinn v Quinn, 4 Mich App 536 (Mich. App. 1966) (clear and positive proof required to overcome presumption)
Erickson Estate, 202 Mich App 329 (Mich. App. 1993) (test for mental capacity to contract)
Robinson v City of Lansing, 486 Mich 1 (Mich. 2010) (statutory interpretation of term 'either party')
McCormick v Carrier, 487 Mich 180 (Mich. 2010) (statutory interpretation and plain meaning guidance)