ULC Court Cases: Ranieri v. Ranieri

Case Background

The conditions surrounding the Ranieri's divorce brought the legality of the ULC's ordination in question in NY.

Rocco J. Ranieri appealed the decision of a Suffolk County, New York court to award Rae B. Ranieri with $500 in pendente lite relief, which is an alimony amount awarded before divorce proceedings have ended to a party in need of financial support, on December 18 1987. Rocco Ranieri was also ordered to maintain Rae Ranieri’s health insurance and health care expenses. Rocco Ranieri argued that the marriage between the two should be declared void due to the fact that an ordained minister of the Universal Life Church solemnized it.

James J. Corrigan, Jr., who received his ordination from the Universal Life Church married Rocco and Rae Ranieri on October 18, 1986. The day before the marriage took place, they executed an antenuptial agreement. They made another agreement that same day in which Rocco Ranieri agreed to pay Rae Ranieri $90,000 within 90 days of being married. The couple was married for 84 days before Rae Ranieri left their residence. On around February 10, 1987, Rae Ranieri asked for a divorce due to Rocco Ranieri’s cruel and inhumane treatment of her. She also sought to have the marriage declared void due to the fact that they had been married by James Corrigan, who had no lawful right as an ordained minister of the Universal Life Church to solemnize their wedding. Her third action was to seek $90,000 from Rocco Ranieri owed to her as stated in their agreement. Rocco Ranieri sought to have the marriage, the antenuptial agreement and the agreement to pay Rae Ranieri $90,000 declared void. He used previous Universal Life Church legal court cases, such as Ravenal v. Ravenal, as an example of a marriage being deemed invalid due to it having been performed by a minister of the ULC.

The court ruled that Corrigan did not have the authority to perform marriage rites because it was declared that the ULC was not an ecclesiastical body or denomination. This conclusion was drawn due to the fact that they did not have a physical church or meeting place intended for worship or for religious observance.

Due to the fact that the marriage between Rocco and Rae Ranieri was deemed invalid, the antenuptial agreement and the promissory note for the sum of $90,000 were also declared null and void. Rocco J. Ranieri argued that since the marriage was declared void, he should not have to pay the pendente lite relief of $500. Rae Ranieri argued that the marriage should be considered legitimate since both parties had believed that the marriage was legitimate when it was performed.

Case Proceedings

The Supreme Court looked into the Universal Life Church and its ordination practices. They took note of several other court cases involving Universal Life Church legal matters. However, they upheld the ruling that any person ordained by the Universal Life Church did not have the right to conduct marriage ceremonies in New York. Because of this, they upheld the decision that the marriage was null and void, and that the antenuptial agreement was as well. According to state law, pedente lite relief could be awarded to a party in the process of terminating a marriage. The law did not specifically state the termination to be divorce, meaning that since they were annulling the marriage, pedente lite could still be awarded.

Rulings And Outcomes

On March 20th 1989 the Supreme Court of New York declared the marriage and Antenuptial Agreement between Rocco and Rae Ranieri null and void. However, they ordered Rocco Ranieri to pay Rae Ranieri pedente lite relief.