Matter of Diaz, 80 N.Y.2d 910 (1992)

A marriage entered into by an incarcerated life-sentence inmate is void from its inception because the legislative declaration of civil death under Civil Rights Law § 79-a imposes a complete disability to enter into a valid marriage.

Summary

This case concerns an article 78 proceeding initiated by a life-sentence inmate, Diaz, challenging the New York State Department of Correctional Services’ (DOCS) determination that he was not legally married for the purpose of participating in the Family Reunion Program. Diaz entered into an out-of-state proxy marriage during his incarceration. The New York Court of Appeals affirmed the Appellate Division’s decision, holding that DOCS correctly applied Civil Rights Law § 79-a. The court reasoned that a life-sentence inmate is under civil death and therefore lacks the capacity to enter a valid marriage. Thus, the proxy marriage was deemed invalid from its inception.

Facts

Diaz was a life-sentence inmate incarcerated in New York State. During his incarceration, Diaz entered into a proxy marriage in another state. Diaz sought to participate in the Family Reunion Program offered by DOCS. DOCS determined that Diaz was not legally married under New York law because of his life sentence.

Procedural History

Diaz initiated an Article 78 proceeding challenging DOCS’ determination. The Appellate Division refused to annul the DOCS determination. Diaz appealed to the New York Court of Appeals.

Issue(s)

Whether DOCS properly applied Civil Rights Law § 79-a as the basis for concluding that petitioner’s out-of-State proxy marriage entered into during petitioner’s life-term incarceration was invalid.

Holding

Yes, because a marriage entered into by an incarcerated life-sentence inmate is void from inception because the legislative declaration of civil death under Civil Rights Law § 79-a imposes a complete disability to enter into a valid marriage.

Court’s Reasoning

The Court of Appeals relied on Civil Rights Law § 79-a, which declares a person sentenced to life imprisonment civilly dead. Citing Ferrin v New York State Dept. of Correctional Servs., 71 NY2d 42, the court stated that this civil death imposes a “complete disability to enter into a valid marriage.” The court reasoned that because Diaz was serving a life sentence, he was civilly dead at the time he entered into the proxy marriage. As such, he lacked the legal capacity to marry, rendering the marriage void from its inception. The court explicitly stated, “A marriage entered into by an incarcerated life-sentence inmate is void from inception because the legislative declaration of civil death under Civil Rights Law § 79-a imposes a *911 complete disability to enter into a valid marriage.” Therefore, DOCS’ determination was correct, and the Appellate Division’s order was affirmed. The decision underscores the continuing impact of civil death statutes on the rights of incarcerated individuals, specifically their ability to enter into legally recognized marital relationships. The decision also emphasizes the principle that individuals deemed civilly dead lack the capacity to contract or exercise certain legal rights, including the right to marry.