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Foreign Law in American Courts

United Arab Emirates Law and Maine Courts

An interesting illustration of how American courts handle (correctly, I think) foreign marriages.

Eugene Volokh | 5.1.2026 9:07 AM

From last week's Maine high court decision in Aldarraji v. Alolwan, written by Justice Julia Lipe, dealing with Ms. Aldarraji's divorce complaint against Mr. Alolwan:

Aldarraji argues that she and Alolwan were legally married under Maine law. Because the parties' marriage ceremony did not occur in Maine, however, the proper question in assessing the legality of the marriage is whether it was valid under the laws of the jurisdiction where the marriage ceremony occurred—here, the United Arab Emirates….

Alolwan was born in Saudi Arabia and is a dual citizen of Saudi Arabia and the United States, having moved to the United States in 2006. Aldarraji came to the United States from Iraq in 2018. The parties met in 2019, and later that year they traveled to Dubai, United Arab Emirates, for a religious marriage ceremony. There was no religious official physically present with the parties in Dubai; an imam affiliated with a mosque in Biddeford, Maine, officiated the ceremony remotely. The ceremony was performed according to the laws of the parties' Islamic faith, and after the ceremony the imam provided them with a certificate of religious marriage.

Soon after, the parties had a wedding reception in Turkey, and on January 16, 2020, while in Turkey, the parties and two witnesses signed the certificate of religious marriage that the imam had provided them. The parties then returned to Maine. They never participated in a marriage ceremony in Maine nor took any steps to validate their marriage in accordance with Maine law ….

Alolwan filed........

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