Section 2.20 License—Necessity and Application

• Library: Family Law Deskbook and 2014 Supp

2. (§2.20) License—Necessity and Application

Missouri is among the states whose licensing statute plainly makes an unlicensed marriage invalid. In Nelson v. Marshall, 869 S.W.2d 132 (Mo. App. W.D. 1993), the couple had a 12-year relationship when the “groom” entered the hospital with a terminal illness. The couple participated in a ceremony before witnesses and the hospital chaplain, but they were unable to have the
3-day waiting period waived to obtain a license because of a legal holiday. The court ruled that no valid marriage existed without the application for or...