Sally L. Untermann, Plaintiff-Appellant v. John Joseph Untermann and Sarah Cayer Kaltman, Also Known as Sarah Cayer…

Summary

The Supreme Court of New Jersey affirmed the trial court's dismissal of the plaintiff's declaratory judgment action, holding that the doctrine of unclean hands barred relief because of the plaintiff's inequitable conduct in obtaining a Nevada divorce, and that the Nevada decree is not entitled to full faith and credit in New Jersey. The Court also held that the Mexican divorce is not recognized and that no common‑law marriage existed. Justice Heher dissented in part, arguing that the Nevada decree should be deemed valid.