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A minor (typically under 18) can disaffirm a contract made, no matter the case.
But some scholars disaffirm that such battles occurred.
Implied ratification is when the conduct of the minor is inconsistent with that of disaffirmance or when minor fails to disaffirm an executed contract within a reasonable period.
In ruling, the presiding Judge stated: "The issue on this appeal is whether an infant model may disaffirm a prior unrestricted consent executed on her behalf by her parent and maintain an action pursuant to section 51 of the Civil Rights Law against her photographer for republication of photographs of her.