In New York, there's case law that ULC ministers don't meet the statutory qualifications for a marriage officiant, and therefore marriages in New York before UL

In New York, there's case law that ULC ministers don't meet the statutory qualifications for a marriage officiant, and therefore marriages in New York before ULC ministers are invalid. But the case in point involved a marriage outside the state, invalid under local law. The city clerk of NYC still registers ULC ministers as officiants and still accepts marriage licenses from them, so the case law is meaningless unless someone raises it in the divorce case.