## Facts

- Fredrick Klusman and Claudia Caswell obtained a marriage license in Pennington County, South Dakota, and were married on December 24, 1984, in a ceremony conducted by an ordained minister with witnesses present.
- The marriage license was never recorded with the register of deeds.
- In October 1986, Fredrick suffered a severe heart attack while traveling and was admitted to St. Joseph Hospital; Claudia signed hospital admission and treatment documents as his wife.
- Fredrick incurred hospital charges of about $14,170, suffered irreversible brain damage, and Claudia later became guardian of his person and affairs until his death in 1989.
- Claudia made regular monthly payments on the hospital bill for nearly eight years, then stopped paying in August 1994.
- Accounts Management, Inc. (AMI), as assignee of the hospital’s claim, sued Claudia for the remaining balance and obtained summary judgment.
- On appeal, Claudia argued she was not liable because (1) the marriage was void due to nonrecording of the license and (2) the charges were not “necessaries” imposing spousal liability.

## Issues

1. Whether failure to record a marriage license renders an otherwise licensed and solemnized marriage void under South Dakota law.
2. Whether a spouse is liable for the other spouse’s hospital and medical expenses as “necessaries of life.”

## Decision

- The South Dakota Supreme Court affirmed summary judgment for AMI.
- The court held the marriage was valid despite the failure to record the marriage license.
- The court held the hospital and medical expenses qualified as “necessaries of life,” making Claudia liable as a spouse for the remaining balance.

## Legal Principles

- South Dakota marriage-licensing and recording statutes are construed to validate marriages when the parties obtained a license and participated in a proper ceremony; an officiant’s failure to record the license does not, by itself, void the marriage.
- The duty to record the marriage license is imposed on the person solemnizing the marriage, and noncompliance by that official does not defeat marital status where the marriage was otherwise lawfully formed.
- Spouses have a mutual obligation for “necessaries of life,” which includes reasonable and required medical care.
- Evidence of the parties’ marital conduct (e.g., signing as “wife,” assuming guardianship, and making long-term payments) supports treating incurred medical charges as necessaries attributable to the marital relationship.

## Conclusion

The court held that an unrecorded marriage license did not invalidate a marriage that was duly licensed and solemnized, and it enforced spousal responsibility for a deceased spouse’s necessary medical expenses, affirming judgment for the medical-debt assignee.


Accounts Mgmt., Inc. v. Litchfield, 576 N.W.2d 233 (S.D. 1998)