New York Court of Appeals

Amy P. Statter v. Humphrey Statter

May 16, 19572 N.Y.2d 668

Summary

The New York Court of Appeals held that the earlier separation judgment is res judicata on the issue of the marriage's validity, thereby barring the wife's subsequent annulment action. The court reasoned that the validity of the marriage was necessarily decided in the first case and that allowing a contrary judgment would impair the earlier judgment. A dissent argued that res judicata should not preclude a trial on the marriage's validity, emphasizing public policy favoring accurate determination of marital status.