Montana Supreme Court

Estate of Hudson

October 7, 2025

Summary

The Montana Supreme Court affirmed the determination that Doug Nail and Carol Hudson formed a valid common-law marriage before Hudson’s death. Applying deferential review of the District Court’s factual findings, the Court held that substantial evidence supported findings of mutual consent and confirmation of the marriage by public repute. The Court concluded that contrary evidence did not establish clear error or a misapprehension of the evidence.