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Bozarth v. Shelton - Trial Court Did Not Err Dismissing Annulment Action

The Virginia Court of Appeals affirmed the Circuit Court of Chesterfield County's dismissal of an annulment action, holding that marriages involving a party mentally incapable of consenting are voidable rather than void ab initio. The court further held that the death of one spouse extinguishes a court's subject matter jurisdiction to terminate a voidable marriage, and that such a marriage cannot be collaterally attacked by a third party after a spouse's death. The plaintiff, as administrator of the decedent's estate, lacked standing to challenge the marriage post-mortem.