Jennings v. Hurt
Supreme Court of New York
N.Y. L.J., Oct. 4 1989, at 24
Sandra Jennings (plaintiff) and actor William Hurt (defendant) lived together from 1981 to 1984, and Jennings became pregnant with Hurt's child while he was still legally married to someone else. After his divorce became final in December 1982, the couple lived together in South Carolina (which recognizes common-law marriage) for a period while Hurt filmed "The Big Chill," during a tempestuous stretch of their relationship; Hurt signed a paternity acknowledgment and, during an argument that same day, allegedly told Jennings he considered them married "in the eyes of God" and "more married than married people." Otherwise, Hurt repeatedly expressed dissatisfaction with the institution of marriage, continued filing tax returns as "single," and the couple never held themselves out publicly as husband and wife. Jennings sued in New York to confirm they had entered a valid common-law marriage in South Carolina.
Whether there is sufficient evidence of a common-law marriage based on a couple's brief cohabitation in a state permitting such marriages, where the alleged husband once stated during an argument that he considered them married "in the eyes of God."