Estate Of Estridge v. Taylor

Facts

H and W both firefighters and EMT/paramedics met in 2011 while employed at the same fire station. H was diagnosed with cancer in 2015, and W was informed of this diagnosis together with other co-workers and mutual friends. H and W started dating and near the end of that year, H first broached the subject of marriage. H proposed to W but she was hesitant to commit. After another marriage proposal in early 2018, W agreed and accepted H's ring. No wedding date was set due to H's upcoming cancer surgery. The couple's friends and co-workers at the fire department were informed of the marriage plans. H and W decided not to tell their family because they were afraid that given the thirty-six-year age difference between them, they would not be accepting of the intended marriage. By mid-2017, an exploratory surgery revealed H was at stage 4, with cancer spread throughout his body. In April 2018, H, accompanied by W, traveled to the University of Chicago Hospital, where he underwent additional surgery. From early on in Estridge's cancer diagnosis, W assisted with his medical care and appointments, and following his 2018 surgery, she assumed further caregiver duties. On April 16, 2019, W accompanied H to have the fluid drained. H's physical condition deteriorated. W drove H to Chicago on April 27, 2019. H's son, Mike Estridge Jr. (Mike Jr.), arrived at the hospital the next day. By May 1, 2019, H was informed that the cancer could not be stopped and that his best option now was palliative care at home. H was prescribed a fentanyl patch for pain control, as well as oral doses of Dilaudid. H's fentanyl patch supplied 25 mcg/hour, with 2 mg Dilaudid every two hours, as needed for pain. H's physician noted that H was able to make complicated decisions, was alert neurologically, and was sitting up in bed awake and alert, though he quickly fell asleep. H asked W if she still wanted to get married. W said yes. A notary witnessed H sign the application for a marriage license. H had always intended W to have his firefighter's pension, because, if he died unmarried, it would go 'back into the till' and he 'didn't want to work that long for nothing[,]' so H also signed a pension benefits beneficiary designation, listing W as his spousal beneficiary. A number of firefighter friends were present and the ceremony was presided over by the firefighter Chief. H, W, and the presiding officer signed the marriage license. Following the ceremony, H was driven to his home, where he signed the Medicaid hospice election form which noted, 'patient very week [sic] and frail. Alert to self. Signed consents with Trisha [Estridge's daughter] and [Mike, Jr.] present.' A firefighter friend informed H's children about the wedding. Mike Jr. suggested to W to get the marriage annulled without telling H and to allow him to pass away happy, thinking he was married. W refused. H passed away four days later on May 6, 2019. P filed a petition to annul the marriage. P filed a petition to annul the marriage alleging fraud and H's mental incapacity. W's expert opined that there was no indication other people were making medical decisions for H. The palliative care physician's observation that H was alert and able to make complicated decisions on the morning of May 2, 2019, and the hospice admission record after the wedding that H was alert to self and signed the hospice consent form. Reflecting on Estridge's narcotics prescriptions, Dr. Rodgers opined that H at his 'baseline' was competent, with no indication of conditions such as dementia, which would render him incompetent. Dr. Rodgers concluded that H was competent at the time of the marriage ceremony; 'Although H looked frail and spoke with a weak voice, 'none of those things are related to competence.' The trial court denied P's petition to annul the marriage. P appealed. 

Issues

Rule of Law

Holding and Decision

Legal Analysis

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