What God Has Joined Together: The Annulment Crisis in American Catholicism

What God Has Joined Together: The Annulment Crisis in American Catholicism

by Robert H. Vasoli
ISBN-10:
0195107640
ISBN-13:
9780195107647
Pub. Date:
04/16/1998
Publisher:
Oxford University Press
ISBN-10:
0195107640
ISBN-13:
9780195107647
Pub. Date:
04/16/1998
Publisher:
Oxford University Press
What God Has Joined Together: The Annulment Crisis in American Catholicism

What God Has Joined Together: The Annulment Crisis in American Catholicism

by Robert H. Vasoli

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Overview

The recent controversy over Joe Kennedy's annulment gave only a glimpse of American Catholicism's open secret: that contrary to official Catholic doctrine, American churches grant annulments wholesale, freely declaring marriages nonexistent so that one or both partners can remarry in the church.
The United States is home to only 6% of the world's Catholics, Robert Vasoli points out, but it now accounts for 75% of all Church annulments, two-thirds of which are granted on ostensibly psychological grounds. The real scandal, though, is not simply the numbers, but that Church marriage courts annul thousands of marriages that are actually valid according to Catholic teaching. Drawing on considerable research, the author details precisely how these courts let divorced Catholics—and many non-Catholics as well—bypass Catholic teaching and law. He shows, for instance, how they often help petitioners manufacture grounds for annulment, which are justified with specious psychological reasoning that are counter to the letter and spirit of canon law. Indeed, it may even be alleged that "lack of emotional maturity" at the time of the wedding can invalidate marriages that have lasted 30 years. The result has been a tidal wave: in 1968, the American church granted fewer than 600 annulments; today it hands out more than 60,000 a year. But Rome has not smiled on the performance of U.S. tribunals: of those psychological annulments appealed to the Roman Rota (the Vatican's highest marriage tribunal), more than 90% are overturned.
This revealing look at annulment weaves painstaking analysis with a wealth of evidence as it illuminates the degree to which the U.S. Church has gone its own way since Vatican II on what constitutes valid marriage.

Product Details

ISBN-13: 9780195107647
Publisher: Oxford University Press
Publication date: 04/16/1998
Pages: 264
Product dimensions: 9.52(w) x 6.44(h) x 1.01(d)
Lexile: 1430L (what's this?)

About the Author

Robert Vasoli is a retired Associate Professor of Sociology at the University of Notre Dame. He is frequently consulted by the media and by laypersons on the issue of annulment. He lives in South Bend, Indiana.

Read an Excerpt


CHAPTER ONE

Profaning Marriage

"Bless me father, for I have sinned. It's been three weeks since my
last confession. I have a problem. My wife left me three years ago and
I attend weekly parish meetings for divorced, separated, and widowed
Catholics. Well, a very attractive woman in the group is hitting on me."

"What's that supposed to mean?"

"She's making sexual advances toward me. I'm tempted to go along with them, but I'm still a married man."

"Have you given any thought to an annulment?"

This colloquy, occurring in the summer of 1995, would have been unimaginable in the pre-Vatican II Church in the United States. The confessor would have told the penitent that the woman's overtures were an occasion of sin, instructed if not ordered him to avoid adulterous entanglements, specified the terms of his penance, and wondered whether the line outside the confessional was getting shorter. The confessor in this case was not newly ordained and thus still under the influence of the latest in pastoral counseling taught at the seminary. He was, in fact, a veteran priest, several years beyond his Golden Jubilee. His leap from carnal desire to annulment ignored or glossed over some highly relevant circumstances: the penitent was not divorced, had no desire to divorce, desperately wanted to reconcile with his spouse, and was still in a marriage that had lasted forty years. He departed the confessional confused, disappointed, angry, and no better equipped morally and spiritually to deal with the recovery group seductress.

    A mere generation ago few American Catholics could identify another Catholic whose marriage had been annulled. Church annulments were rare, perhaps even more so than those granted by civil authorities. In the eyes of the faithful, annulments might be available only to the wealthy or those whose unions did not measure up to rigid tests of validity. Among Catholics whose marriages had failed, annulment was seldom regarded as a realistic option. The more viable choices were to bear one's cross with Christian resignation or, if divorced and already in a remarriage, to remain in the Church without access to the Eucharist or simply drop out.

    In the early 1970s the incidence of annulment began a meteoric rise, increasing at a rate without precedence in Church history. In 1968 the entire American diocesan tribunal system granted fewer than four hundred "formal case" annulments--those requiring trial by a tribunal. Another one hundred or so decrees of nullity were granted administratively, without benefit of trial. Within ten years, hardly an eyeblink in two millennia of Church history, several diocesan tribunals were each issuing more decrees of nullity annually than had been previously granted in any one year by the American Church as a whole. In 1979, for example, the Archdiocese of Chicago's tribunal granted approximately 1,100 annulments, roughly double the total granted by all American tribunals a decade before.

    Today there is hardly any adult American Catholic who cannot point to kin or acquaintances with one or more marriages annulled by Church authority. Exchange a random peace greeting during Mass with a stranger in the next pew and the odds are roughly one in fifty that you shake the hand or buss the cheek of a parishioner who has had at least one marriage voided by a diocesan tribunal. If the person greeted has never been party to an annulment proceeding, he or she will surely know several who were. Whether these probabilities persist in the years ahead cannot be foretold with certainty. But given the current propensity of Catholics to resort to divorce, together with the premises and policies driving America's tribunals, the number of Catholics with annulments will keep inching closer to the number with civil divorces. To arrest the trend would require a radical upheaval within the American tribunal system, to be achieved only by a near-draconian intervention by Rome.

    Viewed cross-culturally, annulment data provide stunning comparisons. The Church in the United States, by a wide margin, has been annulling far more marriages than the rest of the Catholic world combined. In 1980 tribunals worldwide processed 89,065 cases judicially and administratively. Of that number 63,962 (72 percent) emanated from America's busy tribunals. Back then, Vatican statistics published in English did not provide the number of annulments actually granted. Cases processed cannot be equated with decrees of nullity. But at the very least they show that American tribunals were hyperactive compared to tribunals in the rest of the Catholic world.

    Beginning with the 1984 edition, the Statistical Yearbook of the Church provides data on annulments granted and denied per annum as well as on the number of cases processed. The change in reporting was concomitant with the introduction of the revised code of canon law on the first day of Advent in 1983. Ordinarily introductory chapters spare readers the task of poring over tabular data. But a table, like a picture, sometimes can be worth a thousand words. Our pictorial summary of official nullity statistics for 1984-1994 shows with dramatic clarity the magnitude of the problem addressed by this study. It also documents how American tribunals are unrivaled in the issuance of decrees of nullity. Indeed, the disparity between America's annulment output and that of the rest of the world is so striking that the term preeminence understates America's primacy. About 6 percent of the world's Catholic population in the United States accounts for 78 percent of the annulments granted by the Church universal. Breaking the gross percentage into smaller components, we find that American tribunals were responsible for 74 percent of all decrees of nullity reached through ordinary process (i.e., after trial) and 85 percent of those reached through documentary process (i.e., usually administratively, without trial). The latter category consists predominantly of "lack of form" cases, which are virtually automatic decrees of nullity for baptized Catholics who marry outside the Church without proper dispensation. Churches in other English-speaking societies and in western Europe show strong tendencies to move in the same direction the American tribunal system has taken, but do not yet pose a major threat to America's status as the annulment colossus of the world.

    America's disproportionately high contribution to the world annulment total has shown few sips of slackening since its initial upward surge. It is too early to tell whether the data for 1992-1994 foreshadow a long-or short-term trend. More annulments of both kinds were granted in 1994 than 1984. The United States has averaged just under 59,000 recorded annulments annually since 1984. Moreover, the official figures understate the extent to which divorce and remarriage has gained approval within the American Church. Although they are supposed to be exceedingly rare, there are probably thousands of extralegal "annulments" are given out in the United States. Properly speaking, they are "internal forum" solutions rather than annulments, marriages voided de facto without benefit of processing by the "external forum" provided by a Church tribunal. But like "external forum" annulments, they allow recipients to return to the sacraments. It is not terribly farfetched to speculate that between 1980 and 1994 the American Church annulled more marriages than did the entire Church since its founding. At all events, within a relatively brief time frame a sea change occurred in the American Church's approach to the permanence and indissolubility of Christian marriage. Small wonder, therefore, that Archbishop Vincenzo Fagiolo, head of the Pontifical Council for the Interpretation of Legislative Texts, was moved to refer to the volume of annulments in the United States as a "grave scandal."

    Explanations abound for America's quantum leap in the production of decrees of nullity. Demographic and sociocultural attributes of American society are often cited as almost inexorable determinants of the proliferation. Such claims contain kernels of truth. The divorce rate among American Catholics today approximates that of society at large. But to advance a causal linkage between these two variables is simplistic and misleading. In spite of what many canonists maintain, the size of the pool of those eligible for annulments does not necessarily vary directly with increases in the divorce rate, unless one assumes that marriages ending in divorce are usually canonically invalid. Precisely such an assumption is frequently implied or taken for granted by American tribunalists. But in terms of social science methodology the assumption is tenuous and gratuitous. In terms of Church teaching and law, it is untenable, a doctrinal non sequitur. While figures are not available, the vast majority of marriages broken by divorce are in fact certainly valid. The rising frequency of divorce among Catholics increased the demand for nullity, but it is a fanciful and illogical leap to infer a corresponding increase in the size of the pool of deserving eligibles. High rates of separation and divorce also occur among Catholics in other societies, but with far less likelihood of eventual annulment. Finally, Catholics did divorce before Vatican II, but it is quite improbable that the percentage securing decrees of nullity was even close to the percentage that obtains today.

    The heterogeneity of American society is conducive to mixed marriages, which are said to contribute to the heavy flow of annulments. The CLSA's annual statistical summaries provide data on the mixed-marriage cases processed by American tribunals, but the outcome of these cases, whether for or against nullity, is not specified, so really the data merely show that mixed-marriage cases are common. Evidently the reader is supposed to infer that mixed marriages are especially vulnerable to nullity. In fact, however, such marriages, are not ipso facto invalid and indeed can be just as valid canonically as Church marriages between two Catholics.

    Heterogeneity may be a factor in documentary process cases subject to automatic nullity. Unquestionably "lack of form" cases have been on the increase in the United States. It is no secret that some Catholics, fearing marital failure and Church sanctions against remarriage, enter what are in effect trial marriages or marry outside the Church. Along with other documentary process cases (such as those involving the "Privilege of Faith," ligamen [previous marital ties], and unconsummated unions) "lack of form" cases account for about one third of the annulments granted by American tribunals. These kinds of annulments may actually derive more from failures of catechesis and lapses in faith than heterogeneity.

    The sociocultural conditions invoked by the American canonical community to account for the flood tide of annulments might be termed secondary or diversionary variables. They have weak explanatory power at best when it comes to accounting for ordinary process declarations of nullity. Citing them may serve to deflect attention from, or temper, primary variables which are theological, canonical, psychological, and pastoral in nature. Developments in these areas have created a tribunal system committed to facilitating annulment. A salient premise that undergirds the system, one seldom stated for public consumption, is captured succinctly in an anonymous tribunalist's comment: "There is no marriage which, given a little time for investigation, we cannot declare invalid." Many tribunals appear to do their utmost to live by what the anonymous tribunalist preached.

    The system has produced among its theorists and practitioners a collective pronullity consciousness which embodies, among other qualities, righteousness, canonical cleverness, misdirected pastoralism, and arrogance. The reach of this mindset has few boundaries. It can transcend time and space, as evidenced by canonical excursions into history. Thus, one canonist writes that certain contemporary scholars claim that if only Clement VII had availed himself of jurisprudence extant in the sixteenth century, Henry VIII's marriage to Catherine of Aragon could have been annulled. Unwittingly perhaps, the conjecture betrays the tendency of many modern canonists to impute to jurisprudence, even in speculative form, much the same authoritativeness as a pope might claim. It also reiterates, by implication, the contention that every marriage is vulnerable to nullity. A resourceful twentieth-century canonist, transported 450 years into the past, could have done what Cardinal Wolsey failed to do: find in Henry's marital consent and demeanor "personalist" and incapacitating deficiencies to serve as grounds for annulling his marriage to Catherine.

    How Thomas More fits into this hypothetical back-to-the-future scenario is a question that puts imagination to test. It seems improbable that his grasp of sixteenth-century canonical jurisprudence was less sophisticated than that of today's canonists. Not for nothing is he the patron saint of lawyers. His opposition to the king's matrimonial adventurism betrayed no ignorance of Church law. If anything, he understood it only too well. An intellectual exercise more fascinating than projecting today's canonists into the past would be to resurrect Thomas More into the present. After comparing annulment in sixteenth-century England with annulment in post-Vatican II America, he might have become the first saint to achieve martyrdom by losing his mind instead of his head.

    While documentary process annulments have contributed significantly to the skyrocketing annulment output, they are not the focus of this study. The increase in such annulments, unlike the ordinary process variety, did not flow from perceived changes in Church teaching, Church law, and the theology of marriage. We will concentrate on ordinary process decrees of nullity, those granted after trial by tribunal, because they account for most of the sharp rise in nullity decrees. Throughout, our attention will be directed to ordinary process nullity based on defective matrimonial consent, the ground for more than two thirds of annulments granted in the United States. They constitute the form of annulment that raises Rome's hackles and impel Vatican officials such as Archbishop Fagiolo to refer to the volume of American annulments as a "grave scandal." According to Vatican statistics, nearly all ordinary process decrees of nullity declared by the American tribunal system involve forms of defective (invalid) consent. Analysis of defective consent annulments, more than any other research strategy, shows how the United States became the annulment center of the Catholic world. It will also show that defective consent annulments are themselves often defective.

    The first section of the study will survey salient doctrinal, canonical, and pastoral developments that provided the conceptual framework for increasing the number of annulments. The second will treat the psychologization of the annulment process, a trend necessitated by tribunal reliance on defective consent to annul. The third segment will deal with ancillary forces brought to bear by the tribunal system to implement and sustain the blueprint's design for permissive annulment. That portion of the study will examine administrative aspects of the tribunal system which work toward maximizing the production of decrees of nullity. Then will follow an analysis of the plight of respondents in annulment proceedings, along with discussions on the "right of defense" and appellate review.

    Some prefatory comments are in order. The study is made from the perspective of a lay Catholic, a career sociologist whose areas of specialization are the sociology of deviant behavior, the sociology of law, criminal justice, and social psychology. To the best of my knowledge, it is the first study of the American tribunal system conducted by anyone trained in behavioral science. Sociology credentials notwithstanding, I readily concede that Catholicism has transcendental dimensions which are inherently nonempirical, but that does not preclude subjecting many facets of Catholicism to behavioral science analysis. The Church, however otherworldly, encompasses a host of sociocultural structures and procedures amenable to empirical scrutiny. When not dashing off best-selling novels, Andrew Greeley, working out of the National Opinion Research Center, has conducted extensive surveys of Catholic attitudes and behavior. Many others have engaged in similar research. The sociology of religion is a well established specialization within the discipline. Furthermore, behavioral scientists and legal scholars have conducted hundreds of studies of court systems and the administration of justice. The American diocesan marriage tribunals constitute a social as well as juridical system. Their policies, practices, and personnel are all amenable to behavioral science research. As it happens, currently the principal juridical mission of diocesan tribunals is the granting or denying of annulments. Their preoccupation with marriage cases and the attendant burgeoning of decrees of nullity are eminently fit subjects for sociological analysis.

    To an overwhelming degree, scholarly treatment of annulment has occurred within a relatively closed circle. Canonists dialogue with other canonists, theologians trade nuances with fellow theologians, and canonists and theologians display their considerable erudition to each other. An outsider trained in sociology should be able to provide a fresh and useful perspective to understanding annulment in America. This seems to be particularly the case in light of efforts by canonists to use behavioral science in adjudicating defective consent cases. Without going into chapter and verse here, suffice it to say that their dalliance with the human sciences typically shows little sophistication and balance. Seldom does it progress beyond citation of marriage, divorce, and remarriage rates; truisms on the pluralistic character of American society; and vague allusions to social, cultural, and psychological determinants of human behavior. When canonists refer to behavioral science, they usually have psychology in mind. The impression conveyed is that deliberations on the propriety of marital consent are guided by the findings of psychiatry and clinical (or abnormal) psychology. But the system's affinity with psychology turns out to be more catholic. Some tribunals do indeed retain a psychiatrist or psychologist for expert input in defective consent cases, while others settle for a marriage counselor or social worker. The ramifications this has for the annulment process will be analyzed in a subsequent chapter. The point here is that the tribunal system's consort with behavioral science generally gives psychology carte blanche and little more than a wink and a nod to such disciplines as sociology, economics, and anthropology.

    Behavioral science does not deal in absolutes. It gathers data from documents or develops its own through case studies and observation, and by canvassing respondents in samples drawn from larger populations. It collects and analyzes data for tendencies, correlations, and percentage differences, in the hope of testing theories or establishing relationships between specific variables. Impressive as this may sound, its findings are seldom definitive. Not even economics, reputedly the hardest behavioral science of all, trafficks in certainty. The limitations of economic analysis are manifested in perennial discrepancies in annual estimates of the size of the federal budget deficit. Depending on their degree of commitment to aping the physical sciences, behavioral scientists are divided on whether they must be able to predict behavior, seek out its causes, or simply better understand it. Despite these limitations, behavioral science has much to contribute toward making the American tribunal system and its annulment practices more comprehensible.

    What follows here falls within this general framework. It relies primarily on an examination of the annulment literature, canon law, Church statistics on nullity, discussions with many involved in annulment proceedings as tribunalists or parties, and personal experience. There is no way of knowing, with a high degree of confidence, how representative those interviewed are of a much larger universe of petitioners and respondents. I am persuaded that they are not untypical. Most interviewees relate similar experiences, and what they report frequently appears in the literature, especially in decisions handed down in Rome. The study, then, is an effort to identify and analyze trends and patterns that give the American tribunal system its defining characteristics. Generalizations about this or any other system, while based on the best available evidence, require built-in hedges. They do not necessarily apply with equal force to all tribunals and canonists or to every defective consent case. Extraordinarily strong consensus exists among American tribunalists on the pros and cons of annulment, but agreement does not occur at every juncture. It cannot be overemphasized that there are American tribunalists who struggle valiantly for honesty, restraint, and fidelity to Church teaching on the permanence and indissolubility of marriage. Regrettably, their efforts are smothered by the performance of the system as a whole. It also bears repeating that while this study is intended as a system analysis, it will focus primarily on one particular class of annulments--those granted on psychological grounds under the aegis of defective consent. This research strategy derives from two indisputable facts, one quantitative the other qualitative, that require no hedging: the American system turns out more decrees of nullity than any other in the world, and defective consent is the basis for approximately two thirds of the total number produced. It is also virtually coterminous with annulments granted by trial by tribunal. More than any other type, defective consent annulments exemplify the theological and canonical premises that have driven America's tribunal system for nearly three decades.

    Theologians and canonists have contributed much to the Church's understanding of marriage, though certainly not always with the stamp of infallibility. They have also been a source of confusion, at odds with traditional Church teaching and papal pronouncements. In any event, whether viewed as an institution, a sacrament, or a special relationship, the phenomenon of marriage is not their private preserve. Few theologians and canonists marry, and even fewer go through the annulment process as petitioner or respondent. What follows is the handiwork of a lay Catholic and behavioral scientist who experienced marriage and annulment firsthand.

    The book is written in the expectation that it will be received in some quarters as a mean-spirited polemic, an atavistic and perhaps nostalgic retreat to conditions the Church has supposedly outgrown. It might also be regarded as an untimely and unwelcome attack on the post-Conciliar pastoralism, compassion, and nonjudgmentalism so instrumental in Church renewal. The term polemic denotes disputation for its own sake. A polemicist has an ax to grind, an ax honed more with rhetoric than the facts and documentation that are the tools of empirical analysis. Throughout the study an effort is made to let the facts and sources speak for themselves. Since their ability to articulate is imperfect, some interpretative amplification is necessary. Whenever that sort of commentary and analysis is appropriate, I strive to keep it well within the bounds of the evidence. To the extent that it is possible, my motivation is impersonal and always directed toward truth, justice, and the integrity of the sacrament of marriage.

    In the same year Vatican Council II ended, Daniel Patrick Moynihan, an assistant secretary in the Department of Labor, prepared a brief report on the state of the black family in the United States. Moynihan documented the growing fragility of black families, particularly in urban areas. Long before the "feminization of poverty" became part of everyday speech, he envisioned the consequences of unstable families and female-based households. Though intended for limited circulation within the government bureaucracy, the report gained national notoriety. Moynihan was pilloried for allegedly impugning black family morality and dwelling on the untoward effects of broken homes and illegitimacy, but he was far more prophetic than he and his critics realized. If anything, the black family's condition has worsened. Taking one leading indicator, since 1965 the percentage of black babies born out of wedlock has nearly tripled, going from 26 percent to 68 percent. This and other morbidity factors formerly most closely associated with urban blacks are now increasingly common among nonblack families. One of the most striking developments of the mid-1990s has been the emerging consensus that the American family is in woeful shape. The media provide daily reminders of its deterioration with accounts of single-parent families, the feminization of poverty, fatherless children, fathers who neglect child support, child and spouse abuse, and rancorous divorces. Remarkably, this new awareness transcends party, ethnic, and racial lines.

    There is no single definitive explanation for breakdown of the family, but easy divorce is surely a leading cause. Despite the obviousness, very little has been done about it. Government and private agencies have set up hundreds of programs to deal with consequences of divorce, but the primary root cause has gone relatively untouched. The horse has long since fled, yet the barn door remains wide open. Only recently have marriage counselors, once inclined to see divorce as a simple and convenient answer to family problems, come to realize that the antidote might be worse than the disease. The experts are discovering what was long part of folk wisdom: seldom do the scars divorce inflicts on children go away. There appears to be more openness to the traditional belief that spouses in troubled marriages should strive to remain together for the sake of the children, a belief that had been superseded by enshrinement of self-fulfillment and sanguine assumptions on the ability of children to adapt to family rupture.

    Any libidinous, fecund couple can make a child, but families are formed by marriage. Demographically, even with allowance for out-of-wedlock births, families are chiefly responsible for replenishing population. Ecclesially, the family is the principal social unit in which the children of God perpetuate the people of God through the centuries. It is the instrument by which souls are created to give honor and glory to their Creator. Catholics are taught that the family may be considered the domestic Church. "[P]arents, by word and example, are the first heralds of the faith with regard to their children." The family, in short, is the Church's as well as society's primary agent of socialization.

    Tribunals tend to see defective consent annulment as appropriate pastoral and juridical redress for divorce. The causal linkage between these two instruments for ending marriage is commonly regarded as one-directional: annulment is a by-product of divorce. Rarely is it recognized that annulment can cause divorce. Its ready availability often provides inducement to terminate troubled marriages rather than work through the difficulties matrimony presents. The annulment literature contains occasional pieces on the emergence of an annulment mentality among America's Catholics. Left unsaid is the fact that annulment mentality and divorce mentality are kindred states of mind. Together they have the potential for posing a grave threat to the well-being, integrity, and permanence of the family, the "domestic church."

    Crisis has been with the Church since its inception. Peter and Paul did not always see eye to eye. Arianism, the first major Christian heresy, plagued the Church for much of the fourth century. The Dominican order came into being early in the thirteenth century to combat Albigensianism, while the Society of Jesus was formed three centuries later to counter the Protestant Reformation. The list is easily expanded. Ultimately, every crisis faced by the Church, including the outpouring of annulments in the United States, is reducible in one way or another to the overarching issues of faith and authority. Granting their generic primacy, the state of marriage and the family is among more the momentous problems these issues subsume, Annulment, in turn, is a reliable weather vane for the condition of marriage and the family in the contemporary American Church. Its significance was eloquently underscored in Pius XII's address on October 3, 1941 to the Roman Rota:

As regards declarations of the nullity of marriage, everyone knows that
the Church is rather wary and disinclined to favor them. Indeed if the
tranquillity, stability, and security of human intercourse in general
demands that contracts be not lightly set aside this is still more true
of a contract of such importance as marriage whose firmness and
stability are necessary for the common welfare of human society as well
as for the private good of the parties and the children and whose
sacramental dignity forbids that it be lightly exposed to the danger of
profanation.

Although uttered more than a half century ago, Pius XII's words cannot be dismissed as Magisterial dead letter. They reappear verbatim, in John Paul II's 1981 address to the Rota." He quoted them not only to reiterate age-old Church teaching, but also to demonstrate his awareness that the solemn pronouncements of a fairly recent precedessor were being flouted.

    Profanation is a strong term, signifying irreverence, disrespect, desecration, or debasement of something sacred. All these marks of profanation are operative in the American tribunal system. Disinclination to annul has been transmuted into almost irresistible inclination. The chapters that follow will chronicle and analyze how tribunals in the United States are profaning Christian marriage.

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