As noted in the past, officially being married by an internet minister (often cited in NYT wedding announcements) can be tricky. (Becoming one while in prison might be too!) An intermediate court back in the 1980s covering 3/5 of NYC rejected it though the city later on handed out marriage registrant certificates to such ministers. A separate court last year refreshingly didn't go along and remanded the matter for clarification.
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Thanks for your .02!