The State cannot regulate religious marriages, sans a state marriage license. It couldn’t before the SCOTUS enacted toeiva marriage and it certainly cannot now, based on the toeiva marriage decision and the federal court in Utah’s decision.
And Utah’s law was overturned by the federal court on the merits, NOT on a technicality.
It is 100% legal and halachic to have a chupa v’kedushin sans any state marriage license. It isn’t even questionable in the slightest.
And the point was you were wrong in asserting that judicial consent is “rarely given” to marriages for minors under 16. It happens multiple times every year, in every state that permits it. (Which is most states, including NY and NJ.) I doubt it was even requested too many more times than it was granted.