From Pennsylvania appellate court in Adewale v. Adewale, decided by Judge Correale Stevens and joined by Judge Anne Lazarus and Jack Panella on June 22, but just posted on Westlaw in the last couple of days:
Wife claims the trial court erred in determining that the parties' marriage was void ab initio based on its finding that Wife was married to another individual at the time of the parties' purported marriage. {Although we affirm the trial court's order finding the parties' marriage to be void, we refer to the parties as "Husband" and "Wife" for ease of review.} …
The parties were married on April 21, 2011 in Lagos, Nigeria in a ceremony under Nigerian statutory law. {As discussed infra, Nigeria has a plural legal system where different legal systems (statutory law, customary law, and Islamic law) apply to different communities in Nigeria. [Similar systems exist in other countries, including, for instance, Israel. -EV]}
As Wife had become a U.S. citizen after receiving a Diversity Visa through the lottery program in 1999, she filed for Husband's entry into the U.S. as her spouse in 2012. In April 2013, Husband joined Wife in the U.S.; both of the parties are now dual citizens of Nigeria and the U.S….
During the divorce process, "Husband began to question the validity of the parties' marriage as he discovered that Wife may have been married to another person at the time of the parties' marriage," and the trial court explored that:
