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Sam and Lee lived together in State E, which recognizes common-law marriage. They never held a ceremony or obtained a license. After Lee recovered from surgery, the two agreed at home, "From today forward, we are married and will treat each other as spouses." They wore rings, introduced each other as spouses, listed each other as spouses on employment-benefit forms, and filed joint state tax returns. They also told one close friend that they planned to have a public ceremony someday when they could afford it.
Three years later, Sam and Lee moved to State F, which abolished creation of common-law marriages but recognizes marriages validly formed elsewhere. Lee died intestate in State F. Lee's sibling argues that Sam is not a surviving spouse because there was no license or ceremony and because the statement about a future ceremony showed only a future intent to marry.
Discuss whether Sam and Lee formed a valid marriage and whether State F should recognize it.