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Keywords

contractappealworkers' compensation

contractappealwillworkers' compensation

Related Cases

Mott v. Duncan Petroleum Trans., 51 N.Y.2d 289, 414 N.E.2d 657, 434 N.Y.S.2d 155

Facts

Mary and John Mott lived together in Islip, New York, from 1964 until John's death in 1973, presenting themselves as husband and wife. They conducted their financial affairs as if married, and Mary was awarded limited letters of administration as John's 'widow' after his death. However, they were never ceremonially married in New York or elsewhere, and Mary claimed their relationship constituted a common-law marriage contracted in Georgia, despite no evidence of fulfilling their intentions to reside there permanently.

In 1964, Mary and John Mott took up residence together in Islip, New York. From that time until the time of John's death in a work-related accident in 1973, the Motts constantly lived together, in claimant's words 'as husband and wife'.

Issue

Did the Workers' Compensation Board err in failing to properly apply the law of the State of Georgia in determining the Motts' marital status?

The issue on this appeal is whether the Workers' Compensation Board erred in failing to properly apply the law of the State of Georgia in determining the Motts' marital status.

Rule

New York does not recognize common-law marriages except those validly contracted in another state. The law of the state where the marriage occurred must be applied to determine its validity.

It has long been settled law that although New York does not itself recognize common-law marriages… a common-law marriage contracted in a sister State will be recognized as valid here if it is valid where contracted.

Analysis

The court determined that the Workers' Compensation Board incorrectly assumed that New York only recognizes out-of-state marriages previously declared valid and that a mere visit to Georgia could not result in a valid marriage. The Board also failed to consider the Motts' behavior in New York as evidence of their intent to marry, which is relevant under Georgia law. Therefore, the court concluded that the Board applied an improper legal standard.

Based upon the foregoing review of the law of Georgia and of this State, it appears that the determination of the Workers' Compensation Board was premised upon an erroneous view of applicable law.

Conclusion

The court reversed the Appellate Division's order and remanded the case to the Workers' Compensation Board for a redetermination of whether a common-law marriage existed under Georgia law.

Accordingly, the order of the Appellate Division… should be reversed, with costs, and the matter remitted to the Appellate Division, Third Department, with directions to remand for further proceedings in accordance with this opinion.

Who won?

Mary Mott prevailed in the appeal because the court found that the Workers' Compensation Board applied an improper legal standard regarding her marital status.

The court found that the Board applied improper standard of law on issue of marital status of woman necessitating remand.

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