In re the Marriage of Smith

OPINION

This case concerns an alleged “common-law” marriage that Appellant Lilirae Smith (Smith) sought to validate in the Shiprock Family Court (Family Court) after the death of her alleged husband, Leonard Begay, Sr. (Begay). The Court concludes there was a common-law marriage, and vacates the Family Court’s judgment denying the validation.

I

This case concerns a relationship between Smith and Begay. According to the evidence presented to the Family Court, Smith and Begay began their relationship before Smith’s divorce from another man. They took out joint debts, registered and insured a…