Date: 21 Marcheshvan 5561
From: Rabbi Moshe Sofer
To: Mattersdorf
The Chasam Sofer critiques the Chacham Tzvi's doubts about the validity of chalitzah and get performed by a mumar (apostate), and concludes both are valid. He argues that the giving of a get and the performance of chalitzah carry default intent (stam lishmah), that a mistaken understanding of chalitzah's purpose does not negate the mitzvah intent, and that chalitzah—like bi'ah—does not require explicit kavvanas ha-mitzvah.
Source: Shu"t Chasam Sofer EH II §90