Note 1448 — Chapter XVI · A CENTURY AND A QUARTER OF MARRIAGE LEGISLATION IN THE UNITED STATES, 1776-1903 (continued 2)
Reading edition
"Mutual promises to marry in the future, though made by parties competent to contract, and followed by cohabitation as husband and wife, is not, in itself, a valid marriage."—Duncan v. Duncan, 10 Ohio Reports, 181.