A terminally ill firefighter’s marriage days before his death to a woman who was 36 years his junior and the beneficiary of his pension was upheld by the Court of Appeals of Indiana, which found no evidence to support his children’s contention that the nuptials should be annulled because their father’s mental capacity was impaired by pain medication.
Michael David Estridge and Lana Ann Taylor, both firefighters and paramedics, had been involved romantically since 2016 and became engaged in 2018, but they did not set a wedding date. Although they shared the news of their engagement with their colleagues at the fire department, they did not tell their families because they were afraid their relatives would not accept their age difference.
About a year before they started dating, Estridge was diagnosed with cancer. Taylor assisted Estridge with his medical care and appointments and took on caregiver duties. Estridge’s condition worsened until his doctors at the University of Chicago Hospital advised him his cancer was too advanced and his best option was palliative care at home.
Taylor and some of his firefighter friends drove Estridge home to Indianapolis on May 2, 2019. Although he had been prescribed pain medication, Estridge was described by his physician as able to make complicated decisions and alert neurologically. In the car ride home, he was interacting with Taylor and his friends.
During the ride, Taylor asked Estridge if he still wanted to get married. When he said yes, Taylor and the others began calling people to make plans. The couple stopped by the Firefighters Credit Union to get their marriage license notarized, and Estridge signed a pension benefits beneficiary designation listing Taylor as his spousal beneficiary.
When they arrived at the City-County Building in downtown Indianapolis in the late afternoon, they were married by the fire chief. Estridge died four days later.
Estridge’s children were not told of the marriage prior to the wedding ceremony. After Taylor refused to get an annulment, Estridge’s estate filed a petition to annul the marriage, alleging, in part, Estridge’s mental incapacity.
A bench trial was held in Marion Superior Court, with both sides presenting their own experts. Taylor’s expert maintained Estridge was competent, but the estate’s expert told the court he did not have sufficient information to even attempt to determine the groom’s mental competency during the ceremony.
The trial court denied the petition to annul, and the Court of Appeals affirmed in The Estate of Michael David Estridge, Sr. v. Lana Ann Taylor, 21A-DN-1379.
Judge Patricia Riley wrote for the appellate panel, “The trial court was presented with ample evidence and expert testimony from which it could reasonably infer that Estridge was incapable of understanding the nature of the marriage contract he was about to enter into and therefore was mentally competent at the time the marriage was solemnized. … Our review of the same evidence does not unerringly lead to a different conclusion.”
Because Taylor is the pension beneficiary, Estridge’s pension will pay her a monthly benefit of $2,711.34 for the remainder of her life, which equates to about $1.6 million. If the marriage had been annulled, the estate would have received the value of Estridge’s contribution to the pension plan, which would have amounted to about $170,000.
The estate had urged the Court of Appeals to correct the unjust result or the public pension system would be adversely affected because “[e]very single, terminally ill, unretired firefighter would have the power to bestow a great gift on others who have not been — and could not be — accounted for.”
But the appellate panel cited the judiciary’s hesitancy to “inquire into the quality of a marriage” and noted, conversely, that the Indiana General Assembly could take such action.
“Although the legislature statutorily encapsulated the rules for the firefighters’ pension funds, it did not include any limitation on who can be a spouse or the length of time of marriage,” Riley wrote, referring to Indiana Code § 36-8-8-13.8. “Therefore, in the absence of any statutory guidelines to analyze a marriage for quality and quantity attributes such as love, companionship, and length of time, we decline the Estate’s invitation to impose any jurisprudentially.”
However, the COA denied Taylor’s argument on cross-appeal that the trial court abused its discretion in denying her an award of attorney fees.