Michigan Compiled Laws

Mich. Comp. Laws § 552.2 (2026)

Invalidity of marriages; marriage of person under age of consent, marriage by fraud, lack of cohabitation.

✓ current as of July 2026

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Revised Statutes of 1846

R.S. of 1846

552.2 Invalidity of marriages; marriage of person under age of consent, marriage by fraud, lack of cohabitation.

Sec. 2.

In case of a marriage solemnized when either of the parties was under the age of legal consent, if they shall separate during such non-age, and not cohabit together afterwards, or in case the consent of 1 of the parties was obtained by force or fraud, and there shall have been no subsequent voluntary cohabitation of the parties, the marriage shall be deemed void, without any decree of divorce or other legal process.

History: R.S. 1846, Ch. 84 ;-- CL 1857, 3223 ;-- CL 1871, 4734 ;-- How. 6224 ;-- CL 1897, 8617 ;-- CL 1915, 11393 ;-- CL 1929, 12724 ;-- CL 1948, 552.2

PopularName Notes:

No-Fault Divorce

Notes of Decisions

Cited in 7 cases (1 in the last 5 years), 1952–2023 · leading case: Rodenhiser v. Duenas, 818 N.W.2d 465 (Mich. Ct. App. 2012).

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Rodenhiser v. Duenas, 818 N.W.2d 465 (Mich. Ct. App. 2012). · cites it 3× “MCL 552.2 provides that a marriage is void under several other circumstances, including fraud: In case of a marriage solemnized when either of the parties was under the age of legal consent, if they shall separate during such non-age, and not cohabit together afterwards, or in…”

Romatz v. Romatz, 94 N.W.2d 432 (Mich. 1959). · cites it 2× “NOTES [*] We conclude, on reflective examination of CL 1948, §§ 552.2, 552.3 (Stat Ann §§ 25.82, 25.83) (the provisions of these sections date back without essential change to the revised statutes of 1846), that direct and specific statutory authority to hear and determine the…”

Romatz v. Romatz, 78 N.W.2d 160 (Mich. 1956). “81); CL 1948, § 552.2 (Stat Ann § 25.82); CL 1948, § 552.”

Sabourin v. Sabourin, 240 N.W.2d 284 (Mich. Ct. App. 1976). · cites it 2× “Suit began on April 10, 1974, when the plaintiff filed a complaint for annulment, pursuant to MCLA 552.2; MSA 25.82, wherein he alleged that his consent to the marriage to the defendant had been procurred by fraud and that there had never been a physical consummation of the…”

Kim Anthony Burgess v. Linda Lou Burgess (Mich. Ct. App. 2020). “However, any allegation of fraud as grounds to annul the marriage is precluded by MCL 552.2 because the parties voluntarily cohabitated after the marriage.”

20230105_C358735_27_358735.Opn.Pdf (Mich. Ct. App. 2023). “1 and MCL 552.2. The judgment stated that the parties had no children, no real property, and divided their personal property and bank accounts as held in their respective possession.”

Sampson v. Sampson, 50 N.W.2d 764 (Mich. 1952). “The statute of our State, CL 1948, § 552.2 (Stat Ann § 25.82), provides (so far as applicable to the instant case): “In case of a marriage solemnized when * * * the consent of one of the parties was obtained by force or fraud, and there shall have been no subsequent voluntary…”

Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.