Stein v. Stein
Missouri Court of Appeals for the Western District
641 S.W.2d 856 (1982)
Nana Stein (plaintiff) and John Stein lived together in Missouri for about 15 months, holding themselves out as husband and wife without formally marrying. During a three-week bus tour that passed through Pennsylvania -- which does recognize common-law marriage, unlike Missouri -- Nana claimed she and John exchanged rings and vows. After John died, Nana sued his estate (defendant) to be recognized as his surviving spouse and claim a spouse's statutory allowances. The trial court denied recognition of a common-law marriage, and Nana appealed.
Whether a couple who temporarily visits a state recognizing common-law marriage, but resides in a state that does not, becomes married under common law.