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Taylor, age 17, and Riley, age 21, married in State D. State D permits a 17-year-old to marry only with written parental consent and court approval. Taylor's parent signed a consent form, but no court approval was obtained. State D's statute provides that an underage marriage lacking required approval is voidable, not void, and may be annulled only by the underage spouse, that spouse's parent before the spouse turns 18, or a court in a protective proceeding.
Taylor turned 18 six months after the ceremony. Taylor and Riley then continued living together for two more years, renewed their apartment lease as spouses, and opened a joint bank account. Taylor now seeks an annulment, arguing that the marriage was defective from the start. Riley asks the court to treat the marriage as valid and proceed, if at all, by divorce.
Discuss whether Taylor can obtain an annulment and how ratification affects the analysis.