Matter of Watts, 31 N.Y.2d 491 (1973)
The party asserting the existence of a common-law marriage bears the burden of proof, and when the relationship’s inception is meretricious, they must overcome the presumption that the relationship’s character has continued.
Summary
This case addresses whether Louise Lieber and Amandus Watts entered into a valid common-law marriage in Florida, which would then be recognized in New York. The Court of Appeals reversed the Appellate Division’s order, reinstating the Surrogate Court’s decree that no marriage existed. The court emphasized that Lieber failed to establish a prima facie case for common-law marriage under Florida law and did not overcome the presumption that the relationship was meretricious from the beginning, based on documentary evidence and Lieber’s own admissions.
Facts
Amandus Watts died in 1966. Louise Lieber claimed to be Watts’ common-law wife and sought letters of administration for his estate. She presented evidence that they lived together, she wore a wedding ring, cared for him, and were occasionally introduced as husband and wife. However, during 1955-1958, Lieber filed tax returns under her own name. Watts filed tax returns from 1960-1965 without claiming Lieber as his wife and in 1959, reported her as his employee. Lieber voted under her own name and was admitted to a hospital as “housekeeper”. A 1964 letter from Lieber stated, “If I were a wife I couldn’t do more for you.” She later admitted that, but for the executor, they would have married. She was listed as Watts’ housekeeper on funeral forms and filed a claim for services rendered as his housekeeper from 1955 to 1966.
Procedural History
Lieber petitioned for letters of administration in Surrogate’s Court, Hamilton County, claiming to be Watts’ common-law wife. Watts’ distributees and executor contested. The Surrogate’s Court ruled against Lieber, dismissing her petition and objections to Watts’ will. The Appellate Division reversed, but the Court of Appeals reversed the Appellate Division and reinstated the Surrogate’s Court’s original decree.
Issue(s)
Whether Lieber and Watts entered into a valid common-law marriage under Florida law, such that it should be recognized in New York.
Holding
No, because Lieber failed to establish a prima facie case for a common-law marriage under Florida law, and she failed to overcome the presumption that their relationship was meretricious in its inception.
Court’s Reasoning
The court applied Florida law, which places the burden of proof on the party asserting the common-law marriage. Florida law requires either direct testimony of an agreement to marry or, absent that, proof of general repute and cohabitation as man and wife to support a presumption of marriage. The court found that Lieber’s evidence fell short of establishing a prima facie case. Citing *Matter of Alcala* and *Matter of Beacher*, the court distinguished the present case by noting the lack of documentary evidence, such as tax returns, deeds, or insurance policies, supporting a matrimonial relationship. Instead, the documentary evidence refuted the claim. Furthermore, the court reasoned that even if a prima facie case had been established, Lieber failed to overcome the presumption of a continuing meretricious relationship. The 1964 letter suggesting Watts “didn’t want to live in sin” implied the relationship was initially meretricious. The court stated, “A fair inference is that the relationship was meretricious in its inception and such inference is bolstered by the record developed in the Surrogate’s Court. Against this, respondent presented little cogent evidence to overcome the presumption of a continuing meretricious relationship.” The court emphasized that acts inconsistent with marriage, like filing taxes separately and Lieber’s admission of a housekeeper relationship, weighed against her claim. The court referenced *Barretti v. Twomey* a Florida case, to highlight how documentary evidence can refute claims of common-law marriage.