Joan A. Newburgh, as Administratrix Ad Prosequendum for the Heirs at Law of Melvin H. Newburgh, Deceased, and as…

Summary

The Supreme Court held that Joan Newburgh's Mexican divorce was presumptively valid and her marriage to Melvin Newburgh therefore valid, entitling her to a share of the wrongful death proceeds. The Court also found a factual issue as to whether Steven Newburgh is entitled to support for his college and law school education and remanded for further determination. Two concurring opinions noted, with Justice Handler urging an equitable estoppel analysis and Justice Pashman advocating de facto spouse recovery under the Wrongful Death Act.