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HomeMy WebLinkAbout2022-00685 Gibson V Crozier (2) JODY GIBSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION (IN DIVORCE) : DAVID CROZIER, : Defendant : NO. 2022-00685 CIVIL TERM IN RE: DEFENDANTS PRELIMINARY OBJECTIONS TO PLAINTIFFS COMPLAINT BEFORE HYAMS, J. OPINION and ORDER OF COURT Hyams, J., March 21, 2023. 1 In this divorce action premised upon a common-law marriage, in which equitable 2 distribution of marital property is an issue, Defendant has filed preliminary objections to 3 Plaintiffs complaint challenging the existence of a marriage. A hearing on the preliminary objections was held by the court on February 9, 2023. For the reasons stated in this opinion, Defendants preliminary objections will be sustained. STATEMENT OF FACTS This action was commenced by the filing of a complaint in divorce on January 26, 2022. The facts alleged in Plaintiffs complaint may be summarized as follows: Plaintiff is Jody Gibson, an adult individual residing in Mount Holly Springs, 4 Cumberland County, Pennsylvania. Defendant is an adult individual residing in 5 Gardners, Cumberland County, Pennsylvania. The Plaintiff and the Defendant have 1 See Complaint in Divorce, filed January 26, 2022 (hereinafter Plaintiffs Complaint). 2 See Petition for Economic Relief, filed October 4, 2022 (hereinafter Plaintiffs Petition for Economic Relief). 3 Preliminary Objections to Plaintiffs Complaint in Divorce, filed January 11, 2023 (hereinafter Defendants Preliminary Objections). 4 Plaintiffs Complaint, ¶1. 5 Plaintiffs Complaint, ¶2. been common law married since 2003, \[s\]upporting documentation of the common law marriage incudes the \[d\]eed to the marital home, where the parties are listed as Husband and Wife and the insurance card, which lists Plaintiff on Defendants health insurance as 67 a spouse, and they have three children together. 8 At this time, the parties marriage is irretrievably broken. Relief requested by 9 Plaintiff is a no-fault divorce decree pursuant to Section 3301(c) of the Divorce Code, 10 and an equitable division of the parties marital property, including the marital 11 residence where Defendant currently lives. Defendants preliminary objections to Plaintiffs complaint were filed on January 11, 2023. They allege that Plaintiff and Defendant began dating on December 29, 1213 2002, that Plaintiff and Defendant did not declare marriage in or before 2003, and 14 that the parties were never married. It is further alleged as follows: 14. Plaintiff and Defendant held no joint financial accounts. 15. Plaintiff and Defendant consistently declared they were single when filing taxes. 16. In August 2003, Plaintiff, while pregnant with Defendants child, was added to Defendants health insurance as a domestic partner. * * * * 18. In 2007 or 2008, Plaintiff and Defendant became engaged to marry, but this engagement did not result in marriage. 6 Plaintiffs Complaint, ¶4. 7 Plaintiffs Complaint, ¶7. It appears from the record made at the hearing on Defendants preliminary objections that Plaintiff is the parent of one child by a prior relationship and the parties together are the parents of two children. N.T. ___. A transcript of this hearing has not been prepared as of the filing of this opinion. 8 Plaintiffs Complaint, ¶10, 9 Plaintiffs Complaint, ¶10 and prayer for relief. 10 Plaintiffs Petition for Economic Relief, prayer for relief. 11 Plaintiffs Petition for Economic Relief, ¶5. 12 Defendants Preliminary Objections, ¶11. 13 Defendants Preliminary Objections, ¶12. 14 Defendants Preliminary Objections, ¶13. 2 19. Plaintiff remained on Defendants insurance until April 2018, when she was required to produce evidence of their purported common law marriage. 20. Plaintiff was unable to produce evidence substantiating a common law marriage, so her insurance coverage was terminated. * * * * 28. Plaintiff and Defendant never declared they were married. 29. Plaintiff and Defendant maintained separate financial accounts, filed taxes separately, and never co-mingled utilities or other accounts. 30. Plaintiff and Defendant never held themselves out as married. 31. Plaintiff never utilized Defendants last name, as evidence of marriage, but rather used her prior married name in conjunction with her maiden name. 32. When required to produce documents to prove a common law marriage for medical insurance purposes, Plaintiff was unable to produce any documents to evidence the parties were in a common law marriage; therefore, the medical insurance was 15 terminated on Plaintiff. Defendants preliminary objections request dismissal of Plaintiffs complaint on 16 the basis of a lack of capacity to sue for divorce and legal insufficiency of the 17 pleading. As noted, a hearing on Defendants preliminary objections was held on February 1819 9, 2023. At this proceeding, Plaintiff presented the testimony of herself and her father, 2021 and secured the admission of ten exhibits, and Defendant testified on his own behalf 22 and secured the admission of eleven exhibits. The testimony of Plaintiff may be summarized as follows: 15 Defendants Preliminary Objections, ¶¶14-16, 18-20, 28-32. 16 Defendants Preliminary Objections, Count I, prayer for relief. 17 Defendants Preliminary Objections, Count II, prayer for relief. 18 N.T. ___-___, Hearing, February 9, 2023. 19 N.T. ___-___, Hearing, February 9, 2023. 20 Plaintiffs Exhibits 1-10, Hearing, February 9, 2023. 21 N.T. ___-___, Hearing, February 9, 2023. 22 Defendants Exhibits 1-9, 11-12, Hearing, February 9, 2023. 3 23 The parties met on December 29, 2002, and became romantically involved. Following Plaintiffs discovery in July of 2003 that she might be pregnant, they went to a notary public in the third week of August, 2003, and executed a document 24 acknowledging that they were parties to a common-law marriage, thereby facilitating 25 her inclusion on Defendants medical insurance policy. They lived together until June 26 of 2021, punctuated by a seven-month period of separation in 2018, produced two 27 children, and held themselves out to the children in their household, to their other relatives, being referenced by parents as daughter-in-law and son-in-law, and to the 28 public as a married couple, introducing themselves as my husband and my wife. Items representing indicia of the marriage included copies of (a) an insurance card, issued after 2005, pursuant to the health care plan utilized by Defendants employer 29 listing Plaintiff as a named insured, (b) rings given to Plaintiff by Defendant, and a ring 30 given by Plaintiff to Defendant, (c) a deed to the parties residence, recorded December 31 18, 2015, in which the parties were identified as husband and wife, (d) a motor vehicle insurance policy application, dated February 4, 2016, in which they were both to be 32 named insureds, (e) a mortgage, recorded June 27, 2016, in which they were referred to 3334 as husband and wife, (f) a 16th-year anniversary card from Defendant to Plaintiff, (g) 23 N.T. ___, Hearing, February 9, 2023. 24 N.T. ___, Hearing, February 9, 2023. 25 N.T. ___, Hearing, February 9, 2023 26 N.T. ___, Hearing, February 9, 2023 27 N.T. ___, Hearing, February 9, 2023 28 N.T. ___, Hearing, February 9, 2023. 29 N.T ___ and Plaintiffs Exhibit 4, Hearing, February 9, 2023. 30 N.T. ___ and Plaintiffs Exhibit 10, Hearing, February 9, 2023. 31 N.T. ___ and Plaintiffs Exhibit 1, Hearing, February 9, 2023. 32 N.T. ___ and Plaintiffs Exhibit 5, Hearing, February 9, 2023. 33 N.T. ___ and Plaintiffs Exhibit 2, Hearing, February 9, 2023. 34 N.T. ___ and Plaintiffs Exhibit 6, Hearing, February 9, 2023. This card included the language: We are coming to a new year and I cant help but look back and say WTF . . . Everything normal any 4 35 an anniversary card from the three children in their household, and (h) a mortgage related to refinancing, recorded April 29, 2021, in which they were referred to as husband 36 and wife. With respect to the insurance card, it was typical of the cards issued in 2003 and 37 thereafter, evidencing Plaintiffs coverage as Defendants spouse. Of the rings, three had been given by Defendant to Plaintiff in 2005, and the fourth had been given by Plaintiff to Defendant in 2007; as tokens of the parties marriage, Defendant wore his ring, and Plaintiff wore two of her rings every day from 2005 until the parties separated in 2018, put them on again following their reconciliation, and ceased wearing them upon 38 their final separation in 2021. The anniversary card from Defendant was sent to Plaintiff 39 in September of 2018 in the course of the parties separation at that time, and the 40 anniversary card from the children was given to them the same year. In addition, the parties filed a joint income tax return in the year they purchased 41 the aforesaid residence, designating themselves as married, and Plaintiff specified 42 Defendant as the beneficiary on her life insurance policy. Admittedly, however, the 43 parties had also filed separate tax returns in other years, as non-married taxpayers, more. . . . Just know Im always going to consider the last 16 year as my best. . . . Plaintiffs Exhibit 7, Hearing, February 9, 2023. 35 N.T. ___ and Plaintiffs Exhibit 7, Hearing, February 9, 2023. This card included the language:. 36 N.T. ___ and Plaintiffs Exhibit 3, hearing, February 9, 2023. 37 N.T. ___, Hearing, February 9, 2023. 38 N.T. ___, Hearing, February 9, 2023. 39 N.T. ___, Hearing, February 9, 2023. 40 N.T. ___, Hearing, February 9, 2023. 41 N.T. ___, Hearing, February 9, 2023. 42 N.T. ___, Hearing, February 9, 2023. 43 N.T. ___, Hearing, February 9, 2023. 5 44 Plaintiff had never changed her name to that of Defendant, they maintained separate 4546 bank accounts, and they never owned a vehicle jointly. In 2018, a letter was received by Defendant from the administrator of the health care plan provided through his employment advising that a continuation of Plaintiffs health care benefits would require documentation of Plaintiffs status as a common-law 47 spouse. By a subsequent letter dated June 8, 2018, the organization that administered Defendants health care plan sent notice of the termination of Plaintiffs coverage due to its failure to receive an attestation for \[Defendants\] common law spouse to remain 48 enrolled in the program. Reinstatement of the coverage, according to the letter, would require submission of a 2018 Attestation of Common Law Marriage Form; in this regard, paperwork reading as follows was enclosed: 2018 ATTESTATION OF COMMON LAW MARRIAGE We, ___________________ and __________________, the undersigned, hereby attest that each of the following is true and correct: Each of us is the common law spouse of the other. If our common law marriage was established in the Commonwealth of Pennsylvania, each of us spoke words necessary and sufficient under Pennsylvania law to become each others spouse prior to September 17, 2003 \[sic\]. We present ourselves to the community and for all legal purposes as married. This includes but is not limited to filing federal, state, and local taxes either as Married Filing Jointly or Married Filing Separately. If the common law marriage was established outside of the Commonwealth of Pennsylvania, it was established in accordance with the laws of the applicable jurisdiction in which it was entered, and the marriage is recognized by the Commonwealth of Pennsylvania (or the jurisdiction in which we reside) as valid and binding. 44 N.T. ___, Hearing, February 9, 2023. 45 N.T. ___, Hearing, February 9, 2023. 46 N.T. ___, Hearing, February 9, 2023. 47 N.T. ___, Hearing, February 9, 2023; see Defendants Exhibit 6, Hearing, February 9, 2023. 48 N.T. ___, Hearing, February 9, 2023; see Defendants Exhibit 6, Hearing, February 9, 2023. 6 We understand that our marriage may be terminated only through an appropriate court proceeding and that we have not obtained a divorce, annulment, or other dissolution of our marriage. We understand that this Attestation may be used as evidence of our marriage. We hereby agree to provide additional information that the \[plans administrator\] may reasonably request as proof of our marriage. Each of us further agrees to indemnify the \[administrator\] and the Commonwealth of Pennsylvania\[, Defendants employer\], as well as any of the health plans in which we participate or have participated for any expenses, costs, losses, or liabilities of any nature that any of them incurs as a result of any failure of this confirmation to be completely true and accurate or any false statement or other information that either of us has provided in the past with regard to our marital status. Employees Name (Please Print): _______________________ Spouses Name: _____________________________________ Employees Signature: ________________________________ Spouses Signature: ___________________________________ AFFIDAVIT ATTESTING TO THE EXISTENCE OF COMMON LAW MARRIAGE By signing this affidavit below, you represent that you have established a valid marriage under common law. A valid common law marriage is a marriage under state law having all the legal consequences of a ceremonially performed marriage. Not all states provide for the establishment of common law marriage. Pennsylvania does not recognize common law marriages entered into on or after September 17, 2003 \[sic\]. If the relationship you identify below is not a valid common law marriage, you may not, for example enroll your intended spouse for coverage as a dependent under the \[administrator-provided\] Medical Plan. Employee and Common Law Spouse Information We, _____________ and ________________, the undersigned do hereby affirm, under penalty of perjury, that we meet all legal requirements to be married under common law. As evidence of our marriage, we represent that we 1) have cohabited for ____ years; and 2) hold ourselves out to the community as husband and wife; and 3) neither one of us is currently married to another individual; and 4) expressly agreed to and entered into a common law marriage on ___________________ (enter date of marriage). We each sign this affidavit as evidence of our marriage and represent that we have been married since the date in 4) above and have filed federal and/or state income tax returns indicating that we are married. As evidence of our marriage, we agree to provide to the \[administrator of the plan\], through the local HR office, two of the documents identified below. We understand that the \[administrator of the plan\] may copy the documents for its records. The original deed to the employees home, if owned jointly. The original automobile title, if owned jointly. 7 The original statement of a current bank account that is held in joint name \[sic\]. The original copy of the employees Will, identifying the spouse. A copy of the cover page (indicating filing status) and signature page (if a different page) of the employees Federal income tax return, which indicates marital status, from 2002. For privacy reasons, the numbers showing income and deductions should be blanked out. We also agree to provide to the \[administrator of the plan\] a copy of any applicable divorce decree if either of us was previously married. Although Pennsylvania recognizes certain common law marriages, you may obtain divorce only through the appropriate legal process. ________________________ _____________________ Signature of the Employee Signature of the Spouse ________________________ Employee Number On this _________ day of _______________, 20___, before me appeared _______________ and __________________, the affiants who being duly sworn, affirm that the facts contained therein are true and correct and acknowledge that they executed in the same for the purpose therein recited. _______________________________ 49 Notary Public Plaintiff was unable to locate a copy of the original attestation as to the existence of a common-law marriage which the parties had supplied in August of 2003, nor was she 50 able to submit at least two of the supporting documents referred to in the affidavit, and 51 Defendant declined at that time to cooperate in facilitating the process. Plaintiffs father testified at the hearing that his contact with his daughter had been 52 continuous over the past twenty years, that he had always been under the impression 5354 that the parties were married at common law, and that they did everything together. 49 N.T. ___, Hearing, February 9, 2023; see Defendants Exhibit 6, Hearing, February 9, 2023. 50 N.T. ___, Hearing, February 9, 2023. 51 N.T. ___, Hearing, February 9, 2023. 52 N.T. ___, Hearing, February 9, 2023. 53 N.T. ___, Hearing, February 9, 2023. 54 N.T. ___, Hearing, February 9, 2023. 8 He referred to Defendant as his son-in-law, and Defendant called him Dad, according 55 to his testimony. In support of this testimony, Plaintiffs father identified a photograph he had posted on Facebook with an inscription reading Id like to wish my son in law David Crozier a very special Veterans Day, along with my Dad and Brothers in law, Dave and 56 Leroy and all Veteranswith Jody L. Shields-Gibson \[i.e., Plaintiff\]. He identified another of his posts on Facebook, dated August 20, 2020, which read Id like to send out a special Thank You to my son in law David Crozier for helping me get the flagpole back 5758 up. He also noted that Defendant helped \[him\] with everything, that he was taken 5960 on excursions by Defendant, and that he shared every holiday with the parties. The testimony of Defendant at the hearing may be summarized as follows: He had 61 commenced his current employment with the Commonwealth of Pennsylvania in 2000, had consulted the personnel department about including Plaintiff on his health insurance 62 coverage in order to confirm her pregnancy and provide care for his unborn child, and 63 had followed the departments instructions as to acquisition of that coverage. The 64 parties never exchanged marriage vows, were understood by their closer acquaintances 6566 to be unmarried, rarely, if ever, filed tax returns depicting themselves as married, 55 N.T. ___, Hearing, February 9, 2023. 56 N.T. ___ and Plaintiffs Exhibit 8, Hearing, February 9, 2023. 57 N.T. ___ and Plaintiffs Exhibit 9, Hearing, February 9, 2023. 58 N.T. ___, Hearing, February 9, 2023. 59 N.T. ___, Hearing, February 9, 2023. 60 N.T. ___, Hearing, February 9, 2023. 61 N.T. ___, Hearing, February 9, 2023. 62 N.T. ___, Hearing, February 9, 2023 63 N.T. ___, Hearing, February 9, 2023 64 N.T. ___, Hearing, February 9, 2023 65 N.T. ___, Hearing, February 9, 2023 66 N.T. ___, Hearing, February 9, 2023. 9 67 owned no property together other than the house, and maintained no joint bank 68 accounts The ring given to him by Plaintiff represented an engagement ring that she presented to him during a Valentines Day excursion in 2007, accompanied by an explicit 69 proposal of marriage. The deed in which they were identified as husband and wife represented an altered version of the deed provided at settlement, which did not so 70 identify them. The anniversary card from him to Plaintiff represented a commemoration 71 of the date they met, not of a marriage date. And his refusal to facilitate retention of her coverage on his insurance in 2018 was based on the fact that it would have required 72 dishonesty. Indicia of the parties non-marital status included copies of (a) a 2004 Statement of \[Defendant Retirement\] Account naming his mother, and not Plaintiff, as 73 beneficiary, (b) a federal 2005 income tax return in which Defendants status was listed as single, and returns for 2006 and 2007 in which his status was listed as head-of- 74 household, without designation of a spouse, (c) income tax returns of Plaintiff for 2006 75 and 2007 in which her status was listed as single, (d) a domestic relations office conference summary dated March 7, 2006, in a child support case filed by Plaintiff against her ex husband stating that TF LIVES WITH HER BOYFRIEND AND HE 67 N.T. ___, Hearing, February 9, 2023. 68 N.T. ___, Hearing, February 9, 2023. 69 N.T. ___, Hearing, February 9, 2023. 70 N.T. ___, Hearing, February 9, 2023. In Defendants recollection, the deed provided at settlement, which he had assumed was the recorded instrument, was revised without his knowledge to correct the name of the seller and, in the process of revision, revised the status of the grantees to that of husband and wife. 71 N.T. ___, Hearing, February 9, 2023. 72 N.T. ___, Hearing, February 9, 2023. 73 N.T. ___ and Defendantxhibit 11, Hearing, February 9, 2023 74 N.T. ___ and Defendants Exhibit 1, Hearing, February 9, 2023. 75 N.T. ___ and Defendant2, Hearing, February 9, 2023. 10 76 WORKS, (e) a 2010 discharge of Defendant as a debtor in bankruptcy proceedings to 77 which Plaintiff was not a party, (f) a 2015 deed conveying the parties prior residence, 78 from Defendant, its owner, as a single man, (g) the 2015 deed to the parties residence produced at settlement, which identified each of the grantees simply as an 79 adult individual, of even date with the deed recorded identifying them otherwise, (h) an application for a loan to Plaintiff dated December 20, 2018 (during the parties 80 separation) identifying Plaintiffs then-landlord as DAVID CROZIER -EX, and (i) paperwork from Defendants personnel file, issued around October 24, 2022, describing 81 his marital status as \[s\]ingle. Admittedly, Plaintiffs father had referred to Defendant as his son-in-law, and 82 Defendant on occasion referred to him as Dad. In addition, Plaintiff would sometimes introduce Defendant as her husband, and Defendant would not correct the statement 83 when she did so. Finally, about half of the parties acquaintances probably thought that 84 they were married. At the conclusion of the February 9, 2023, hearing on Defendants preliminary objections to Plaintiffs complaint, an order was issued providing for the submission of 8586 briefs on behalf of the parties. Briefs have now been filed. 76 N.T. ___ and Defendants Exhibit 9, Hearing, February 9, 2023. 77 N.T. ___ and Defendant7, Hearing, February 9, 2023. 78 N.T. ___ and Defendantbit 3, Hearing, February 9, 2023. 79 N.T. ___ and Defendants Exhibit 4. 80 N.T. ___ and Defendant8, Hearing, February 9, 2023. 81 N.T. ___ and Defendant5, Hearing, February 9, 2023. 82 N.T. ___, Hearing, February 9, 2023. 83 N.T. ___, Hearing, February 9, 2023. 84 N.T. ___, Hearing, February 9, 2023. 85 Order of Court, dated February 9, 2023 (Hyams, J.). 86 See Defendants Brief in Support of Preliminary Objections, filed March 7, 2023; Plaintiffs Brief in Opposition to Defendants Preliminary Objections, filed March 9, 2023. 11 DISCUSSION Statement of law. Although no \[Pennsylvania\] common-law marriage contracted 87 after January 1, 2005, is valid, those contracted before that date remain legitimate. See Costello v. W.C.A.B., 916 A.2d 1242 (Pa. Cmwlth 2007). The burden of proof with respect to the existence of a common law marriage rests upon the proponent of the marriage. In re Estate of Carter, 2017 PA Super 104, 159 A.3d 970. This burden has been characterized as vy, \[w\]hen an attempt is made to establish a marriage without the usual formalities, the claim must be reviewed with great scrutiny. Staudenmayer v. Staudenmayer, 552 Pa. 253, 262, 714 A.2d 1016, 1020 (1998). The formation of a common-law marriage has been described by the Pennsylvania Superior Court as follows: To create a common-law marriage, there must be an exchange of words in the present tense, verba de praesenti, spoken with the specific purpose that the legal relationship of husband and wife be thereby created. Commonwealth v. Smith, 511 Pa. 343, 352, 513 A.2d 1371, 1375-1376 (1986), cert. denied, Smith v. Pennsylvania, 480 U.S. 951, 107 S.Ct. 1617, 94 L.Ed.2d 801 (1987). Because it is hard to prove such verba de praesenti, there is a rebuttable presumption of marriage where two essential elements exist: constant, not irregular or inconstant, cohabitation plus a broad and general, not partial or divided, reputation of marriage. In re Estate of Rees, 331 Pa. Super. \[225,\] 228, 480 A.2d 327, 328 \[1984\]. Cohabitation and reputation are merely circumstances from which the existence of a contract of marriage can be inferred and not requisites per se to prove a common-law marriage. In re Estate of Kovalchick, 345 Pa.Super. 229, 235, 498 A.2d 374, 377 (1985). Commonwealth v. McLean, 387 Pa. Super. 354, 364, 564 A.2d 216, 220-21 (1989).!! The \[common law\] marriage contract does not require any specific form of words, and all that is essential is proof of an agreement to enter into the legal relationship of marriage at the present time. Estate of Gavula, 490 Pa. 535, 540, 417 A.2d 168, 171 (1980).!! Stated differently, common law marriage will still be recognized without use of verba de praesenti, where the intention of the parties\[,\] as expressed by their words, is that they were married. In re Estate of Carter, 2017 PA Super 104, ¶__, 159 A.3d 970, 979 (citation omitted). 87 23 Pa. C.S. 1103. 12 The proof requisite for a finding of a common law marriage has been said to be partially disjunctivein nature; ewed equationally, the elements \[can be\] expressed as common-law marriage = verba de praesenti or = (rebuttable presumption: constant cohabitation + general reputation).Commonwealth v. McLean, 387 Pa. Super. 354, 364, 564 A.3d 216, 221 (1989). Thus, it has been said to be error to require proof of verba de praesenti and proof of constant cohabitation and general reputation which is unrebutted, for a finding of a common-law marriage. Id. However, the Pennsylvania Supreme Court has clarified the law as follows: . . . We have starule which permits a finding of marriage duly entered into based upon reputation and cohabitation alone is one of necessity to be applie In re Nikitkas Estate, 346 Pa. 63, 65, 29 A.2d 521, 522 (1943). Thuction of evidence concerning cohabitation and reputation of marriage is the inability to present direct testimony regarding the exchange of verba in praesenti. We held in In re Estate of Stauffer, 504 Pa. 626, 476 A.2d 354 (1984), that the Dead Man's Act prohibited the purported wife's testimony regarding the exchange of marital vows with her alleged common law husband. There, we noted that the inability of the putative widow to present any testimony regarding the exchange of vows did not prevent her from proving a permits a finding of marriage based upon reputation and cohabitation when established by satisfactory proof. Id. at 632, 476 A.2d at 357. We have not, however, dispensed with the rule that a common law marriage does not come into existence unless the parties uttered the verba in praesenti, the exchange of words in the present tense for the purpose of establishing the relationship of husband and wife. See Commonwealth v. Wilson, 543 Pa. 429, ___, 672 A.2d 293, 301 (1996) (discussing common law marriage in context of a claim of spousal testimonial immunity). We have allowed, as a remedial measure, a rebuttable presumption in favor of a common law marriage based on sufficient proof of cohabitation and reputation of marriage where the parties are otherwise disabled from testifying regarding verba in praesenti. However, where the parties are available to testify regarding verba in praesenti, the burden rests with the party claiming a common law marriage to produce clear and convincing evidence of the exchange of words in the present tense spoken with the purpose of establishing the relationship of husband and wife, in other words, the marriage contract. In those situations, the rebuttable presumption in favor of a common law marriage upon sufficient proof of constant cohabitation and reputation for marriage, does not arise. By requiring proof of verba in praesenti where both parties are able to testify, we do not discount the relevance of evidence of constant cohabitation and reputation of marriage. When faced with contradictory testimony regarding verba in praesenti, the party claiming a common law marriage may introduce evidence of constant cohabitation and reputation of marriage in support of his or her claim. We merely hold that if a putative spouse who is able to testify and fails to prove, by clear and convincing evidence, the establishment of the marriage contract through the exchange of verba in praesenti, then that part 13 marriage, since he or she does not enjoy any presumption based on evidence of constant cohabitation and reputation of marriage. See Pierce v. Pierce, 355 Pa. 175, 181, 49 A.2d 346, 349 (1946) (\[p\]roof of reputation and cohabitation could not establish marriage; nor, in the absence of evidence regarding a marriage contract, is it sufficient to warrant a presumption of marital relat Staudenmayer v. Staudenmayer, 552 Pa. 253, 263-65, 714 A.2d 1016, 1021 (1998) (footnote omitted); see Perrotti v. Meredith, 2005 PA Super 57, 868 A.2d 1240. A deed in which the parties are identified as husband and wife provides some independent corroborative evidence of a common-law marriage proponents testimony, but is not necessarily dispositive of the issue. Staudenmayer v. Staudenmayer, 552 Pa. 253, 266 n.9, 714 A.2d 1016, 1022 n.9 (1998). Nor is an affidavit of the parties attesting to a common-law marriage for purposes of obtaining insurance coverage necessarily conclusive. Bell v. Ferraro, 2004 PA Super 144, 849 A.2d 1233. Application of law to facts. As is often true, in this case \[t\]he difficulty is not with 88 the law, but in the application of it. With respect to credibility, the court believed that the witnesses at the hearing testified as to their recollections to the best of their abilities, and without any attempt at misdirection. It appeared to the court that Defendants recollection that the 16th-year anniversary card he sent to Plaintiff in 2018 was intended to commemorate the date that they met in December of 2002 rather than the August, 2003, date when they attested to the existence of a common-law marriage was probably 89 more accurate than Plaintiffs, given the language \[w\]e are coming to a new year. In addition, the court found Defendants testimony as to the revision, without his knowledge, of the 2015 deed to the parties residence, as well as the testimony he gave as to his motivation for declining to participate in the process of perpetuating Plaintiffs 90 inclusion on his health insurance coverage, to be credible. 88 Knouse v. Knouse, 6 Northumberland Law Journal 15, ___, 3 Pa. D. & C. 534, 535, 1922 WL 4017, 1922 WL 4017, at 2 (1922). 89 See note 34 supra. 90 In this regard, however, it must be noted that the insurers criteria for proof of a common-law marriage are not to be equated with legal requirements. 14 On the merits, in the courts view two factorstendedtodepreciate the strength of Plaintiffscase. First, the evidence of an eventin which verba in praesenti,or their equivalent, wereexchanged by the parties, was weak, at best.And, second, the record wasreplete with instances in which the parties did not characterize themselves as married. With regard to the first factor, thepartiesattestation ofmarriage in August of 2003to facilitate Plaintiffs inclusion on Defendants health insurance coverage was, in the courts view, more in the nature ofarepresentation of the existenceof a common-law marriage, for a particular purpose, than theformation of one.The evidence respecting this eventdoes not appear to satisfy the conditionfor recognition of a common-law marriage set forth inStaudenmayer,where both parties are available to testify. Withregard to the second factor,the partiesinconsistencies in characterizations of theirmarital status werenot compatible with a broad and general,not partial or divided,reputation of marriage,requisite for circumstantial proof of a common-law marriage. Given that the burden ofproving a common-law marriage is aheavyone, and thata claim of the existence of a common-law marriage is to be subjected to great scrutiny,the court does not find itselfin a position to deny Defendants preliminary objectionsto Plaintiffs complaint.Accordingly, the following order will be entered. ORDEROF COURT st AND NOW, this 21day of March, 2023, upon consideration of Preliminary Objections to Plaintiffs Complaint in Divorce, filedby DefendantonJanuary 11, 2023, following a hearing held on February 9, 2023, and for the reasons stated in the accompanying opinion, Defendantspreliminary objections are sustainedand Plaintiffs complaint is dismissed. BY THE COURT, ________________ Carrie E. Hyams, J. 15 DISTRIBUTION: Jane Adams, Esq. 17 W. South Street Carlisle, PA 17013 Attorney for Plaintiff Kara W. Haggerty, Esq. LAW OFFICES OF PETER J. RUSSO, P.C. Suite 102 245 Grandview Avenue Camp Hill, PA 17011 Attorney for Defendant 16