## Facts

- Edith L. Renshaw applied for Title II Social Security widow’s insurance benefits after Albert Renshaw’s death, claiming she was his common-law wife.
- Edith and Albert, both divorced from prior spouses, began living together on July 5, 1958, initially in Maryland, without a ceremonial marriage.
- Edith testified they agreed to live as though married and considered themselves husband and wife.
- They cohabited for about 21 years, largely in Buffalo, New York, had one child, and never separated.
- They consistently held themselves out as married, including Edith’s use of Albert’s surname, joint tax returns, and Albert’s designation of Edith as his wife and beneficiary on a life insurance policy.
- Their relevant contacts with Pennsylvania occurred during roughly eight round trips (1968–1975) to visit relatives in the South, when they repeatedly stayed overnight at a Pennsylvania motel and represented themselves there as husband and wife.
- The Secretary of Health and Human Services denied benefits, concluding Edith was not a common-law spouse under Pennsylvania law; the district court affirmed.

## Issues

1. Whether, under Pennsylvania law, Edith and Albert formed a valid common-law marriage during their Pennsylvania stays so that Edith qualified as Albert’s “widow” for Title II benefits.
2. Whether the Secretary’s finding that no Pennsylvania common-law marriage existed was supported by substantial evidence.

## Decision

- The Second Circuit reversed the district court’s judgment and remanded to the Secretary for further action consistent with the opinion.
- The court held that Edith and Albert entered into a valid Pennsylvania common-law marriage.
- The court concluded the Secretary’s contrary determination lacked substantial evidence given the governing Pennsylvania standards and the record.

## Legal Principles

- Title II widow status is determined by reference to state law; when the domicile state recognizes marriages validly formed elsewhere, an out-of-state common-law marriage can satisfy the federal “widow” requirement.
- New York does not create common-law marriages but recognizes a marriage valid where contracted; thus, a valid Pennsylvania common-law marriage would be recognized for benefit eligibility.
- Under Pennsylvania law (as described by controlling state authority), a claimant bears a heavy burden to prove common-law marriage, but the marital contract may be shown by circumstantial evidence, including long cohabitation and a broad reputation of marriage.
- Short or episodic physical presence in Pennsylvania does not categorically bar formation of a common-law marriage when evidence shows an ongoing marital agreement and the couple cohabited and held themselves out as married within Pennsylvania.
- In Social Security cases, appellate review applies the substantial evidence standard to the agency’s factual determinations; an agency conclusion inconsistent with the governing state-law framework and the evidentiary record cannot stand.

## Conclusion

The Second Circuit held that the record established a Pennsylvania common-law marriage, which New York would recognize, so Edith qualified as Albert’s widow for Title II benefits; the denial of benefits was reversed and remanded for agency action consistent with that determination.


Renshaw v. Heckler, 787 F.2d 50 (2d Cir. 1986)