Supreme Court of Colorado

In Re the Marriage of Edi L. Hogsett v. Marcia E. Neale

January 11, 2021478 P.3d 713

Summary

The court refined Colorado's test for establishing a common-law marriage, holding that the parties must mutually intend to enter the legal and social institution of marriage and must engage in conduct manifesting that agreement. Applying that framework, the court concluded that the evidence showed a committed relationship but did not establish mutual intent because Neale did not intend to marry. The court therefore affirmed the court of appeals' judgment affirming dismissal of Hogsett's dissolution petition.