Judging invalidity the American way
By Sheryl Temaat

And there came to him some Pharisees, testing him, and saying, “Is it lawful for a man to put away his wife for any cause?”  But he answered and said to them, “Have you not read that the Creator, from the beginning, made them male and female, and said, ‘For this cause a man shall leave his father and mother, and cleave to his wife, and the two shall become one flesh’?  Therefore now they are no longer two, but one flesh.  What therefore God has joined together, let no man put asunder.”

  They said to him, “Why then did Moses command to give a written notice of dismissal, and to put her away?”  He said to them, “Because Moses, by reason of the hardness of your heart, permitted you to put away your wives; but it was not so from the beginning.  “And I say to you, that whoever puts away his wife, except for immorality, and marries another, commits adultery; and he who marries a woman who has been put away commits adultery” (Matt. 19:3-10), (my emphasis).

 By these words, the Lord teaches that those who divorce and remarry commit adultery.  But his words are almost meaningless today.  Catholics who divorce since Vatican II, and desire to remarry in a Catholic Church, almost automatically apply to the diocesan tribunal for a declaration of nullity, and in most cases, they receive one.

 There are few Catholics today who are the unfortunate victims of divorce who live celibate, single lives remaining faithful to the vows they took for better or worse until death.  I personally know seven such people.  These friends of mine suffer derision and ridicule by many who see no useful purpose for their remaining single.

 Most Catholics today approve of remarriage after divorce, with or without a declaration of nullity, and it is the annulment process itself, I would argue, that has promoted this attitude.

 Fr. Lawrence G. Wrenn, a canonist with the Hartford, Connecticut, diocesan tribunal, is considered the leading expert today among diocesan tribunalists on how to apply the teachings of Vatican II to the annulment process.  His books are published by the Canon Law Society of America.  Three notable ones are: Decisions, 1983; The Invalid Marriage, 1998; and Judging Invalidity, 2002.  A canon lawyer with whom I spoke told me that these books by Fr. Wrenn are used as textbooks in university canon law courses.

 In order to illustrate my point that the annulment process has promoted the idea that Catholics can divorce and remarry like anyone else in society, I will be using Fr. Wrenn’s latest book Judging Invalidity, 2002, in this article.

 Judging Invalidity is about fifteen fictional cases, one for each of the basic grounds that are heard by tribunals in formal trials in the United States. The grounds are:  male impotence, lack of due discretion, lack of due competence, error of substance (ignorance), error of quality, imposed error, determining error, total simulation, intention against children, intention against fidelity, intention against perpetuity, intention against sacramentality, condition, force and fear, and defective convalidation.  Of the fifteen cases, I have reviewed seven, all of which were granted decrees of nullity.  My comments are in italics.

Lack of Due Discretion, p. 7
 The case of Charlotte Dotterel and Stanley Weaver is described under Lack of Due Discretion.  They are both Catholic, were married in a Catholic Church in 1992, were divorced four years later and have no children.

 According to my research, lack of due discretion or defective matrimonial consent is the ground for more than two thirds of annulments granted in the United States.  In the Preface to his book, Fr. Wrenn writes that “each decision aims to be an instruction on the kind of evidence to be collected, how that evidence is to be evaluated, and how the jurisprudence is to be applied to the available evidence” (p. v)  (My emphasis).

 Stanley Weaver declined to participate in the Tribunal proceedings in his case, so the arguments are going to be one-sided.  Nevertheless, Fr. Wrenn judged Charlotte’s evidence as well as that of her three witnesses, her father, her friend Betty, and her brother as “entirely reliable” (p. 10).  How can evidence from only one side be judged as “entirely reliable?”  It certainly makes it more than ordinarily difficult to attain moral certainty about the nullity of the marriage.  Hearing the other side in any argument can dramatically change the whole picture.

 Under The Argument, pp. 10-11, Fr. Wrenn writes that “once married, the negative aspects of Stanley’s personality began to surface.”  Don’t you think that the negative aspects of Charlotte’s personality also began to surface?   All married people whom I have known have shown their best side before marriage; this is the way it is.

 Charlotte’s father described Stanley as “extremely arrogant and selfish, that he had an ‘I don’t need anyone else’ attitude, and that he was callous, cold and was constantly belittling Charlotte for being ‘stupid’.”  While it’s not nice to call someone “stupid,” I don’t know where it’s considered evidence for declaring a marriage null.  There are men in long-term marriages who can be described the way Charlotte’s father described Stanley.  And wouldn’t it be fair to argue that Stanley had some good qualities that these people chose to ignore?  And that Charlotte was able to provoke the kind of behavior in Stanley that others criticized?

 Charlotte’s friend Betty pointed out that during the marriage, Charlotte and Stanley lived off Charlotte’s income while Stanley saved his own salary in a personal account. I know a couple who have been married over thirty years who started out their marriage this way.  When did this become evidence for nullity?  To use the way Stanley saved his salary suggests that couples are required to handle their finances a certain way in order to have a valid marriage.

“Betty also noted that Stanley felt superior to everyone else and that he would spend at least a couple of hours a day working out in the gym, that he seemed obsessed with his body, and seemed to prefer his time in the gym to spending time with Charlotte.” How is it that Betty can read Stanley’s mind and knows that he “felt superior to everyone else?”  Did Stanley work out in the gym before marriage?  The way things “seemed” is not necessarily the way things were.  Again it would only be fair to ask what Charlotte did to provoke Stanley’s attitudes and actions?  Still I cannot see any of this as evidence for nullity. If it is, 90% of marriages are invalid.

Charlotte’s brother said that “Stanley’s priorities were first his career, second his working out at the gym, and third his marriage to Charlotte.  It was, at any rate, always Stanley’s own needs and wants and no one else’s that counted in Stanley’s mind.” This is more evidence that amounts to reading Stanley’s mind.

 “Charlotte testified that Stanley tended to ignore even his parents at times.  On one occasion, she reported, when his parents came from upper New York State to visit them, Stanley was extremely uncordial and went off for a couple of hours to the gym, ignoring even his parents who had been so good to him.”  I would have to ask if this is the entire picture of this visit or did positive events occur as well.  Did Stanley return from the gym and take his parents and Charlotte out to dinner?  Above all, what does this incident have to do with the validity of a marriage?

 Fr. Wrenn finishes The Argument segment of this case with the following:

Charlotte did her best to cater to Stanley [so she says, but would he?], but he seemed uninterested in spending time with her, and after a year and a half or so of marriage he would say, “there must be something else out there for me.”  The “something else” soon turned out to be a woman by the name of Veronica with whom he had an affair.  The affair continued, eventually with Charlotte’s knowledge, for about a year, and finally, in July of 1995, Stanley told Charlotte that he was leaving her to be with his beloved Veronica [Why does Fr. Wrenn refer to her as “beloved?”  She’s a partner in adultery.]; and off he went, without apologizing and simply telling Charlotte that their marriage had been a mistake (p. 11).

  How does calling a marriage a “mistake” contribute to evidence for invalidity?  Calling a marriage a mistake at best indicates imprudence, which is not lack of due discretion.  It seems to me that these people are involved in sin, and that that is the issue, not whether they had a marriage and can marry again in the Catholic Church.

 Furthermore, it is strange that Charlotte put up with Stanley’s affair for a year, but this fact strongly indicates that Charlotte did not experience Stanley’s character defects as gravely disturbing married life.

 Stanley was diagnosed with a Narcissistic Personality Disorder by Dr. Philip Continga, M.D., the court appointed psychiatric expert.  John Paul II, in his 1987 and 1988 allocutions to the Rota, specified that both grave lack of due discretion and lack of competence must be predicated on a serious psychopathology (anomaly).  Fr. Wrenn has a penchant for trying to make all sorts of marital difficulties fit this standard.  To refer to Narcissistic Personality Disorder as a serious psychological disorder is ludicrous.  It simply means that a person is self-centered, which many of us are in one way or another.  At one time or another.

 Furthermore, there is no evidence in Wrenn’s book that Philip Continga, M.D. adheres to a “Christian anthropology,” (Anthropology here means the study of human nature), as Pope John Paul II has required in addresses to the Rota (1979-2003).  Specifically, the Holy Father requires that the expert must possess a Christian anthropology so that he will be able to recognize the difference between usual difficulties and those which make married life impossible for one’s partner.

 The fact that Stanley left Charlotte for another woman within three years of marriage makes me wonder if he vowed fidelity.  Maybe he did and maybe he didn’t.   But surely lack of due discretion is contrived in this case.

Lack of Due Competence, p. 12
 Under Lack of Due Competence, Wrenn discusses the case of Melissa Mallard and Bradford Tattler, both Catholic who were married in 1986 in a Catholic Church.  They lived together in marriage for 14 years and had two children.

 Wrenn writes that “Melissa, however, always seemed depressed, unhappy, and dissatisfied” (p. 12). Was she always depressed, unhappy and dissatisfied or is she saying that now because she wants to divorce and remarry in the Catholic Church?  Who is always depressed, unhappy and dissatisfied?  My guess is that Melissa and Bradford had many happy times together, but when people want out of a marriage, they tend to focus on the negative.

 Wrenn continues to argue that she felt like a prisoner in the marriage and remained only because it would have been socially incorrect to end the marriage.  How about morally incorrect?  How about bad for the children?

 Bradford testified that Melissa “tried to be a good wife” (p. 16).  This seems to be evidence that the marriage is valid.  He complained, however, that when their first child was born, Melissa focused her attentions entirely on the baby and in a sense married the child and used the child as a substitute for her husband.  Husbands have complained for centuries that the baby gets the attention that they used to get.  When did this become useful as evidence for invalidity?

 Melissa testified that her father died when she was five, and when she married Bradford “she was still yearning for a father’s love” (p. 16).  Aren’t we all “yearning” for something?  If this is evidence for invalidity, how can she ever marry validly?

 On page 13 Wrenn writes:  “In our tribunal the teaching has now been accepted which requires not only the capacity of assuming the three obligations but also the ability to assume the partnership of life ordered to the good of the spouses, which is considered by some (see Pinto) as a kind of a fourth bonum, and by others as an essential element of marriage as suggested by canon 1101.” But has this fourth bonum been accepted by the Church?  How could it be?  That would destroy the teaching on indissolubility.

 Fr. Wrenn is notorious for seizing on single cases, like that of Pinto above, that suit his permissive annulment ideology and according them landmark status, while ignoring contrary Rota decisions, as well as instructions by the Holy Father.  John Paul II has explicitly deemed the bonum coniugum and the partnership of life (a communion of life and love) as ends, not essential goods of marriage.  But U. S. Tribunals, like Fr. Lawrence G. Wrenn’s, continue to grant annulments on the basis of Canons 1055 and 1057.

 A declaration of nullity was granted on the basis of incapacity for the bonum coniugum on Melissa’s part.  This definition of the bonum coniugum serves tribunals well and devastates family life.  Any marriage that runs into difficulties, and most do at one time or another, can be laid to rest at the tribunal cemetery --declared null because of lack of due competence.  This is simply horrendous.

 On page 14, Fr. Wrenn writes, “A radical incapacity for placing interpersonal relationships blocks the bonum conuigum  since it becomes impossible to assume and fulfill conjugal obligation.”  He adds that “the typical difficulties that are found in almost all marriages are not sufficient to prove this incapacity” (p. 14).   However, a careful study of his books shows that anything beyond burned toast is evidence for nullity.  If a man has a period of emotional instability due to job pressures compounded by lack of sensitivity on his wife’s part, it’s off to the divorce court followed by the tribunal.

 Children can just suffer the loss of their family.  They aren’t allowed to see parents grow beyond the hardships and difficulties that at one time or another come upon most families.

 Could a respondent argue that the capacity for the bonum coniugum existed at the time of marriage?  (Pretending for a moment that there really is a fourth good of marriage.)  Not according to Wrenn who argues that “a particular disorder [which] was latent in the subject prior to marriage, surfaced during the marriage in reaction to certain influences”  (p. 15).

 That’s like saying we never would have known that Melissa lacked due competence for marriage if Bradford had not given her gifts.  If this sounds ridiculous, an affiant of Bradford testified that Bradford tried to please Melissa with gifts, “but that Melissa was never satisfied with a gift and ‘tended to rub Brad’s nose in the things he gave her’” (p. 17).  To say that she never liked any of his gifts is extreme; surely she liked something.  But to use such a petty example as evidence in marriage validity proceedings is outrageous.

Other evidence in this case accepted by the Hartford tribunal includes the following:

• Margo Pintail, Ph.D., counselor: “Melissa was not able to achieve the desired companionship and intimacy with her husband that he was interested in achieving” (p. 17).   No one promised these people anything.  They, on the other hand, made solemn promises, vows, for better or for worse until death, and their salvation depends on their keeping those vows.  Wrenn avoids commenting on the issue of salvation.

• Philip Cotinga, M.D., the court appointed psychiatric expert reported that Melissa “suffered from low self-esteem, self-absorption, and a need for attention and admiration.  She lacked empathy and feared intimacy but, at the same time, felt deprived of the love and affection that other couples had”  (p. 18.)  These people watch too many soap operas.  Much of the evidence for invalidity in Fr. Wrenn’s books is simply the human condition; we fall, we get up, we try again, and over and over until death parts us, not the Tribunal.

Error of Quality, p. 24
 Stephanie Quetzel and Leonard Harrier, both Catholic, were married in May 1991 and lived together in marriage for a little more than three years.  They got along quite well, Fr. Wrenn writes, but had no children, and when it was medically determined that Leonard’s sperm count was so low that he would not be able to father children, Stephanie told Leonard that she loved him and that it would be with much regret and pain that she would be leaving him.  She apologized to Leonard for the hurt that she knew her actions would cause him, but she felt that she was called to be a mother, and so would petition for divorce and then search for a husband who would be able to give her children.

 The declaration of nullity was granted because the Tribunal was satisfied that it had been proven 1) that Stephanie’s desire for children was deep seated, life long, all important and perhaps obsessive; 2) that she was in error when she thought that Leonard was fertile; 3) that the quality of fertility is objectively grave, and was, for Stephanie, extremely grave; and 4) that Stephanie directly and principally intended to marry a fertile man, which she erroneously thought Leonard to be.

 Stephanie was quoted in the testimony as saying, “I will go to my grave plagued with guilt that I broke this wonderful man’s heart because of something that was no fault of his, but once I learned he was sterile, it was almost like I had no choice because this for me was not a marriage.  It just wasn’t what I intended when I married and I knew I had to leave” (p. 28).

 These people decide quite easily what is not a marriage, and it doesn’t matter who the casualties are.  This seems to me to be a particularly cruel decision.  Are we now required to have fertility testing done prior to the marriage to insure validity?  Why didn’t anyone counsel Stephanie that adoption could be considered?

 Wrenn adds that the most pertinent circumstantial evidence in this case is that, less than two years after her divorce from Leonard, Stephanie entered a second marriage before a Justice of the Peace and now has two children from that marriage.

 Stephanie told Leonard that “she loved him. . . and would be leaving him.”  She was “called to be a mother. . . and search for a husband who would be able to give her children.”  Petitioners normally want annulments in order to be able to enter into a valid Catholic marriage.  How could Stephanie’s marriage to the second man possibly be valid when her only criteria is fertility?

 Furthermore, for Stephanie to admit, “It just wasn’t what I intended. . . .” what if she had intended to have only one child, and ended up with twins?  Or she wanted only two children and had a third pregnancy?  Would she know “I had to leave,” or would she have had an abortion?  Would she have divorced Leonard because “it just wasn’t what she had intended?”

 Fr. Wrenn is willing to rely on CIRCUMSTANTIAL evidence that “less than two years later” she went before a Justice of the Peace and now has two children.  Evidence of what?  That she was fertile and entitled to bear children?

 Furthermore, Fr. Wrenn calls it a marriage when a Catholic marries before a Justice of the Peace when the Catholic Church has traditionally referred to this as an attempted marriage.  If Fr. Wrenn can refer to what Stephanie entered before a Justice of the Peace as a marriage, why can’t he declare marriages null for any reason whatsoever?

 This decision is particularly offensive because a valid Catholic marriage requires an “openness” to children, not a requirement that children be born of that relationship.  If Fr. Wrenn aims to have “each decision. . . be an instruction,” look at the slippery slope this decision leads us down.

 Come to think of it, Henry VIII was denied an annulment on the argument that Catherine of Aragon was unable to conceive.  A sane appellate Tribunal would reverse this decision.

Imposed Error, p. 30
 Daniel Bunting and Joanne Stilt, both Catholic, were married in April 1995, and lived together in marriage for two and a half years.  At that time, however, Daniel discovered that Joanne had deceived him at the time of the wedding about whom it was that she had had a baby with before their marriage.  One child was born of their marriage.

 Wrenn writes that “the marriage went well until September of 1997 when Daniel, while looking for something else, happened across a letter written in 1992 from Eugene to Joanne in which it was clear that it was Eugene and not some nameless soldier who had fathered Joanne’s child” (p. 35).

 Daniel was devastated because he and Eugene were very close friends.  He confronted Joanne with the evidence and she broke down in tears and begged Daniel’s forgiveness, but staying in the marriage seemed beyond Daniel.  He felt betrayed and humiliated. The decree of nullity was granted on the ground of imposed error.

 That a decree of nullity was granted in this case baffles me.  Why wasn’t Daniel counseled to forgive when Joanne begged him to forgive her?  Isn’t forgiveness of others required of us in order to obtain our own forgiveness?

 What about the child of Daniel and Joanne?  Is granting a declaration of nullity, in this case, as in so many that Fr. Wrenn writes about, so important that the welfare of children is not even considered?  One child born to Joanne has already suffered the fate of not living with its biological parents.  It is my humble opinion that these couples should be encouraged to reconcile, not given decrees of nullity so that they can go on to ruin the lives of their children and make the same mistakes again.

 Furthermore, Daniel was willing to accept a child whose father was a “nameless soldier,” but couldn’t accept the fact that Joanne actually knew the name of the father.  That sounds as if he would rather have had Joanne be so promiscuous as not to know the father’s name but couldn’t bear the fact that she actually could name the father. Why didn’t anyone suggest that Daniel simply drop Eugene as a friend, rather than drop his wife and destroy his family?

Intention Against Perpetuity, p. 59
 In this case, Brian and Adelaide were civilly married in 1989, then had their marriage validated in a Catholic Church in 1990 at the insistence of Adelaide’s parents.  Wrenn writes:

Adelaide’s motive for having the marriage validated was, purely and simply, pressure from her parents, who were furious that their daughter had entered a civil marriage.  A civil marriage was, for them, the same as mere cohabitation and constituted living in sin, and every chance they got they let Adelaide know, in the strongest possible terms, exactly how they felt.  Adelaide’s uncle, furthermore, who was a priest, while less judgmental and more diplomatic, likewise urged the young couple to consider having the marriage validated.  (My emphasis)

 Fr. Wrenn goes on to say that the priest uncle was “less judgmental” and “more diplomatic.”  Many priests’ attitudes are that parents shouldn’t over concern themselves with these matters while the parents are frantic that their daughter will not only ruin her life here but suffer the loss of heaven as well.  This isn’t a good time in history to be worried about the indissolubility of marriage or the hereafter.  Those who are concerned, carry their burden alone.   The decree of nullity in this case was granted because Adelaide did not believe in the Church’s teaching on indissolubility of marriage.  However, disbelief is in the intellect, but intention is in the will, and the will is free to follow or reject belief.  So, it is possible?it happens every day in countries affected by the divorce mentality?that non-Catholics, who obviously hold the same disbelief, enter marriage validly if, as a matter of fact, they do intend to remain together forever.

 The question, then, is what effect the “fury” of Adelaide’s parents had on her will.  The fury reminds one of reverential fear, which, if sufficiently grave, would invalidate a marriage, but that is not the ground of nullity in this case.

Intention Against Sacramentality, p. 65
 Sheila Longspur and Jeffrey Wigeon, both Catholic, were married in a Catholic Church in 1976, lived together 14 years, had two children and divorced in 1991.

 The declaration of nullity was granted because Sheila and her “soul sisters” testified that she had a great deal of anger toward the Church and never intended “sacramentality” when she married Jeffrey.  The evidence included the fact that she “was the middle of three children in the family, and always felt somewhat neglected.

 “Her mother seemed to favor her older sister and her younger brother, but Sheila’s major problem was with her father whose attention she sought but could never win.  She desperately craved his affection and would perhaps have settled for his recognition, but the father, for the most part, ignored her” (p. 70). When are these people going to get over blaming their parents for their own failures?

 Wrenn goes on to say that in college Sheila and Jeffrey’s relationship was sexual (they were fornicating—my words, not Wrenn’s).  Wrenn’s comment is, “Jeffrey was not able to bring much real joy into Sheila’s life but this fortunately was supplied by the three young women who became her soul sisters.  It was they really who were Sheila’s great emotional support during her college years.”

 The issue for Fr. Wrenn is joy and emotional support, not sin and lack of grace.  There isn’t a hint in three of his books, Decisions, ’83; The Invalid Marriage, ’98; and Judging Invalidity, 2002;  that the Catholic Church and the marriage contract is first of all about salvation.  “Holy Orders and Matrimony are directed towards the salvation of others; if they contribute as well to personal salvation, it is through service to others that they do so” (CCC #1534).   Nowhere does the Catechism claim that marriage should be all unending happiness.

 Under The Judicial Confession, Wrenn writes that Sheila explained to the Tribunal that her parents begged her to marry in the Church because her civil marriage to Jeffrey was not recognized by the Church nor would it be by them, which sounds reasonable of her parents.

 Her first thought about marrying in the Church, Sheila told the Tribunal, was that she probably owed it to her parents since they had paid for her college education.   “And her second thought was that, maybe, by so doing, her father might bestow some smidgeon of kindness on her.

 “Sheila never told her parents of the intense antipathy she felt for the Church but privately she seethed that she had agreed to the church wedding, and she told her three friends, ‘You can be sure I won’t be receiving any sacrament.  I don’t believe in that sh?.’  Sheila was clearly embarrassed in offering this testimony to the Tribunal and apologized for the vulgar expression.  She also mentioned that even her three friends were obviously shocked at the vehemence of her remark those many years ago, but as always they were supportive” (p. 70).

 I’m appalled that Sheila’s three friends were shocked at her vehement hatred toward the Church “but as always they were supportive.”  Those aren’t friends.  They are the worst kind of enemy, operating under the guise of flattery.  The Tribunal should have recognized that Sheila was just looking for attention from these three friends in exactly the way that the Tribunal believed that she was seeking attention from Jeffrey and her father.  The Tribunal rejects Jeffrey but accepts the three friends as valid witnesses.

 “This, in essence, is the evidence in this case.  We have this explicit and graphic judicial confession of the simulator, repeated extrajudicial confessions before three confidantes, and adequate motive for a church marriage and a convincing motive for simulating” (pp. 70-71). The Hartford Tribunal was convinced that Sheila had “excluded sacramental dignity by a positive act of the will” (p. 71).

 With specific reference to the ground in this case, let it suffice to refer to the Pope’s 2001 Address to the Rota in which he warned that Tribunals cannot introduce requirements of intention or faith for the sacrament that go beyond that of marrying according to God’s plan from the beginning.  The position of the Tribunal is not to ask whether Stephanie received the sacrament but whether she contracted a valid natural marriage.

 She would have had to reject explicitly and formally what the Church intends to do when the marriage of baptized persons is celebrated.  A remark made in spite to three friends who may not even be recalling facts accurately qualifies as an explicit and formal rejection.

 Furthermore, I wish there were concern here for the two children.  Rather than declare such a marriage null, I would like to see Tribunals encourage reconciliation.  Imagine the happiness of these two children should their parents reconcile.  Shouldn’t that be our goal as People of God?  People do do that.  And very few find happiness in a second marriage.  Even fewer children find happiness when their parents marry a second time.

Condition, p. 72
 Anne Shrike and Anthony Thrasher, both Baptists, were married in a Baptist church in 1997.  They were together in marriage for three years, had one child, and divorced because Anthony was “domineering” and “controlling.”

 Under The Argument, the issue in this case was whether Anthony married Anne only on condition that she quit working and stay home to care for their children.  It should be remembered, first of all, that ordinary engaged couples do not think of technical things like making the validity of a marriage depend on the fulfillment of a condition.  So this could hardly be considered grounds for nullity.

 Furthermore, how can it be considered  unreasonable that a good man would want his wife to stay home and care for the children?  Yet Fr. Wrenn leaves that impression when he writes about this case.

 After Anne had their first child, however, she told Anthony that she was putting the child in day care and going back to work.  The declaration of nullity was granted on the basis of the “condition” placed on consent?that is, that Anne be a full time mother.  Fr. Wrenn commends her independence, “By this time Anne had gained some independence and, in the autumn of 1999, she told Anthony that she had decided that she was going to return to work and put Andrew in day care” (p. 75).

 The declaration of nullity was based on the testimony of three of Anne’s friends who “had personally heard Anthony expound his views on religion and marriage and specifically on the importance of the wife not being employed outside the home once children came along” (p. 76).

 Here we write off another child’s welfare and his parents’ marriage because of what seems to be unlawful grounds for declaring a marriage invalid.

 Note: Anne wanted the declaration of nullity because now she wants to marry a Catholic and become one herself.  Again, where is the evidence that second marriages work out better than first and that they are good for the children of first marriages?

Fr. Lawrence G. Wrenn teaches that Catholics only have to remain in a marriage if things are going their way.  This is the impression that I get from his description of many of the cases he writes about in Judging Invalidity.

A final word
 I don’t write as a canon lawyer but as one who has been married for over 40 years and has experienced much of what Fr. Wrenn calls evidence for invalidity and what I call Life.

 I invite readers to order a copy of Judging Invalidity and see for themselves that much of the book is as evil or more so than what I have covered here.  It can be ordered from the Canon Law Society of America, 301-362-8197.  The cost is $20.95, plus shipping costs of $11.75.

 The kinds of evidence that Fr. Wrenn teaches is useful for granting declarations of nullity is also used by couples to give up on their marriages and by society to dismiss the sacredness of marriage vows.

 Some argue that people getting married today aren’t properly catechized, that the culture we live in doesn’t teach them to value commitment so they don’t know how to do that, and that they lack integrity and maturity.

 But I argue that information is available today as it has never been available before.  Hardly anyone can claim invincible ignorance about the Church’s teachings today.  But above all what is so difficult about understanding words like, “For better or worse, richer or poorer, in sickness and in health until death do us part”?

 These words are simple enough that fourteen-year-olds can understand them.  However no one can be perfect enough today to survive a Petitioner’s efforts to have his or her marriage declared null by most American diocesan tribunals.

 There is hope, however.  First of all, parish priests can counsel couples to preserve their marriages and avoid the tribunal’s lax methods.  Msgr. Clarence Hettinger argues in the December 1993 Homiletic and Pastoral Review that too many tribunals are issuing invalid annulments.  This is an issue of salvation.  Parish priests can deal with it at their level and encourage couples to keep the vows that God will judge them by.  Some want to hear that, and others need to hear it.

 Second, when a tribunal issues an affirmative decision, Respondents can appeal to Rome for a review of their case and a probable reversal of that decision.  Tribunalists at the Roman Rota seem to take a dim view of the treatment that marriage vows get in the American Church.

 One judge, a former Defender of the Bond at the Supreme Tribunal of the Apostolic Signatura argues that there can be sufficient discretion for entering a valid marriage even when a person is judged by psychiatric experts to be in the incipient stage of schizophrenia since it is not yet a psychosis.

 A person can be half crazy, in other words, and still possess sufficient discretion to enter a valid marriage.  Fr. Wrenn argues, on the other hand, that being described as arrogant and selfish, saving one’s salary in a personal account, and working out in the gym are evidence of lack of due discretion.

 As I understand it, Rotal jurisprudence requires serious reasons for issuing declarations of nullity, whereas Fr. Wrenn is willing to include nearly everyone.  Fr. Wrenn is willing to harden hearts.

Mrs. Bill (Sheryl) Temaat lives in Monument, Colorado.  She earned a Masters degree in education at Regis University in Denver.  She is a substitute teacher in the public schools and a free-lance writer.  Her last article in HPR appeared in January 2003.