In Re the Marriage of Dean Lafleur v. Timothy Pyfer

Summary

The court held that Colorado courts may recognize a common-law same-sex marriage entered before same-sex marriage was formally recognized because the exclusionary laws were unconstitutional and void from inception, and the constitutional rule applies retroactively. Applying the updated common-law-marriage framework, the court affirmed that the parties formed a common-law marriage in 2003. It nevertheless reversed the property division and spousal-maintenance award because the district court did not properly classify and value property or make the required statutory findings, and remanded for reconsideration.