Coates v. Watts’s Empirical Analysis
1993
Citation profile
11 state decisions
How this case has been cited
Cited by 12 later decisions — most recently April 2019
11 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc. · Glidden Company v. Zdanok Et Al. · Beard v. Goodyear Tire & Rubber Co. · United States v. A Parcel of Land with a Building Located Thereon at 40 Moon Hill Road · D.D. v. M.T.
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[Wjhen one of the parties to the alleged marriage asserts its existence but either denies or fails to say there was mutual consent or agreement, then mere cohabitation, even though followed by reputation, will not justify an inference of mutual consent or agreement to be married. Although there is no set formula required for the agreement, the exchange of words must “inescapably and unambiguously impl[y] that an agreement was being entered into to become man and wife as of the time of the mutual consent.” Coates’ testimony, if credited, established at most that he and Ms. McCall had, by the end of her life, agreed to be married at an unspecified future time. In light of the authorities cited, this is insufficient to establish the existence of a common law marriage, and the trial judge correctly so held.”
2 later decisions quote this exact passage“) (internal quotation marks omitted). Adhering to Obergefell and Jackson , we now restate the elements of common law marriage as follows: cohabitation following an express mutual agreement, which must be in words of the present tense, to be permanent partners with the same degree of commitment as the spouses in a ceremonial marriage. Echoing Coates , we declare that”
1 later decision quote this exact passage“[a]lthough there is no set formula required for the [express mutual] agreement, the exchange of words must inescapably and unambiguously imply that an agreement was being entered into to become [permanent partners with the same degree of commitment as the spouses in a ceremonial marriage] as of the time of the mutual consent.”
1 later decision quote this exact passage
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.