In Re the Marriage of Rose Williams, Petitioner and Respondent and Dennis Williams, Respondent and Appellant

Summary

The court held that a retroactive decree invalidating Rose Williams’ subsequent marriage did not automatically revive Dennis Williams’ former obligation to make house payments under the dissolution decree. It adopted a flexible equitable approach under which reinstatement may occur only after a proper application and a determination that reinstatement is clearly and persuasively necessary to remedy serious inequity or injustice. The court reversed and remanded for a hearing and findings concerning the effect of the annulment on Dennis as a third party.