DOYLESTOWN — A Bucks County judge has upheld the legality of a marriage performed by a Universal Life Church minister, the latest ruling on whether marriages performed by clergy without a regular congregation are valid under Pennsylvania law.

Bucks County Judge C. Theodore Fritsch Jr. declared the 2005 marriage of Jason and Jennifer O'Neill valid, even though the minister — the groom's uncle — had been ordained in a matter of minutes after completing a short Universal Life form online.

The test case is one of at least three filed across the state by the Pennsylvania chapter of the American Civil Liberties Union to clarify the type of clergy recognized under the Pennsylvania Marriage Act.

Fritsch found the sole question to be whether someone meets the Pennsylvania Marriage Act criterion that a minister, priest or rabbi have "a regularly established church."

He ignored the issue of whether that requires a church building or regular congregation.

The ACLU argues that such a requirement would exclude Jesuit professors, rabbis at college Hillels, and other ordained church authorities, as well as clergy who are retired or assigned to hospitals and military posts.

Fritsch's ruling is binding only in Bucks County, although the ACLU has won similar victories in recent months in Montgomery and Philadelphia counties.