Drach v. Drach

9 Ohio N.P. (n.s.) 353, 1910 Ohio Misc. LEXIS 187
CourtHamilton County Court of Insolvency
DecidedFebruary 17, 1910
StatusPublished

This text of 9 Ohio N.P. (n.s.) 353 (Drach v. Drach) is published on Counsel Stack Legal Research, covering Hamilton County Court of Insolvency primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Drach v. Drach, 9 Ohio N.P. (n.s.) 353, 1910 Ohio Misc. LEXIS 187 (Ohio Super. Ct. 1910).

Opinion

Warner, J. (orally).

In this case the plaintiff has sued for divorce and alimony, alleging as grounds extreme cruelty and gross neglect of duty.

She alleges in her petition a common law marriage on the 17th day of January, 1906, and cohabitation thereafter for somewhat over three years.

As substantiating the grounds for divorce and alimony she alleges desertion on the part of the defendant, Louis Drach, when at one time she asked 'him to refund to her certain monies which she alleged she had given to him. She also alleges a conspiracy between her husband and a man by the name of Reilley, I think, by which she was sent to California and left there without means; that' she has been arrested without warrant and without right at the instigation of her husband, and certain other allegations are made which, if shown to be true, would doubtless constitute gross neglect of duty.

[354]*354The first question raised in this case relates to the matter of common law marriages in this state, and it is claimed that possibly there is some doubt as to whether a common law marriage is valid in Ohio.

I shall not take any time to discuss that question, for I am satisfied from the decisions of the Supreme Court of Ohio in two cases, the Carmichael case in the 12th O. S., and the Duncan case in the 10th O. S., that common law marriages in Ohio are recognized by the law of this state.

As the common law is the foundation of the law of the state of Ohio, it follows that until the Legislature in its wisdom declares against the validity of common law marriages that they must, when proven, be enforced by the courts of the state.

The serious question that has been presented in this case arises upon the contention that no common law marriage is shown by the evidence as presented to the court.

There are two ways in which a common law marriage may be shown. One is specified in the statute on divorce and alimony in this state wherein it is enacted that proof of cohabitation and reputation may be given, and may be sufficient in the opinion of the court to establish marriage and justify subsequent divorce. This is, perhaps, the usual way in which common law marriages are determined to exist.

It will be observed that where the proof relates to cohabitation and reputation that evidence is not introduced of the original contract, but the original contract is assumed and presumed to exist from the fact- of cohabitation and reputation, and this kind of evidence being purely presumptive may be rebutted by other evidence, and when this occurs it becomes the duty of the court under such circumstances to determine whether or not under all the evidence a common law marriage should be presumed to exist in the case. ' ■

The other mode of showing the existence of a common law marriage is to prove the contract by direct evidence thereof, and when the contract is proven, clearly and decidedly, no evidence under the common law is required as to subsequent cohabitation or reputation to establish such contract.

[355]*355Bouvier defines a common law marriage as follows:

“At common law no particular form of words or ceremony was necessary. Mutual assent to the relation of husband and wife was sufficient. Any words importing a present assent to being married to each other were sufficient evidence of the contract. ’ ’

And Mr. Kent in his Commentaries says:

“If the contract be made per verba de presentí, and remains without cohabitation, it amounts to a valid marriage.”

And Chief Justice Folger of the New York Court of Appeals in 1880 held:

“A man and a woman who are competent to marry each other —without going before a minister or a magistrate, without the presence of any person or a witness, with no previous public notice given, with no form of ceremony, civil or religious, and with no record or written evidence of the act kept, and merely by words of present contract between them—may take upon themselves the relation of husband and wife and be bound to themselves, and the state, and society. ’ ’

These eminent authorities establish beyond a doubt what the common law of the United States is as to marriage.

No doubt has been thrown upon these definitions by any decision in the state of Ohio except, perhaps, the case of Carmichael v. State, in the 12th O. S.; brut that was a criminal case in which the party being charged with bigamy was1 on trial, and remembering the well known rules of evidence and law applicable to criminal cases, it is at least doubtful whether the same rule would apply in cases of this kind.

In that case the only doubt thrown upon the definitions quoted was the statement of the court that publicity and reputation were material in showing the intent of the parties to establish the relation of husband and wife, and as in criminal cases the intent is always a matter -to be determined the court well may have said what it did say in regard to that point without intending any conflict with said authorities.

But in that ease there was actual publicity followed by long cohabitation. The party who was indicted' was found guilty [356]*356of bigamy upon evidence that a common law marriage had taken place first and that a statutory marriage had taken place after-wards during the life of the wife by the first marriage.

Some doubt may perhaps have been thrown upon the ques-tion as to the necessity of cohabitation and reputation by the Bates ease in one of our circuit counts, but it is not sufficient to have overturned the common law rule so well established in this country. It is a mere' doubt at best, and until the Legislature of the state speaks the rule.as quoted can not be considered as abrogated.

I speak of this simply for the purpose of clearing away some of the confusion that has crept into the reports by a failure to observe the clear distinction between proof of the contract by direct evidence thereof, and presumptive proof of the contract by the acts of the parties thereafter.

Marriage under the common law is a civil contract, and is subject of course to the usual rules which apply to contracts between parties—strictly construed in the case of marriage, which is regarded as a more important and sacred contract than others.

Now coming.to the facts in this case, was there a common law marriage within the definitions which I have given and within the purview of the law as it has been administered in the state of Ohio?

The defendant, Drach, had known the plaintiff for some time prior to this alleged marriage. He had followed her to California where she had gone attending to the turf matters in which she was interested, her race horses and matters connected therewith, and after he reached California he put up at the same hotel as the plaintiff and shortly thereafter proposed marriage. He did this more than once. He urged the plaintiff to marry him, and the fact that he repeated the requests gives point to the statement of the plaintiff that she at first refused. She says that he said that he would commit suicide, and in that way publish her to the world if she did not marry him. He denies the suicide threat but admits that he did several times ask her to marry him. There is no dispute about this. Finally it appears that she consented to marry him, and there is no dispute [357]

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Bluebook (online)
9 Ohio N.P. (n.s.) 353, 1910 Ohio Misc. LEXIS 187, Counsel Stack Legal Research, https://law.counselstack.com/opinion/drach-v-drach-ohctinsolvhamil-1910.