Note 656 — Chapter XVIII · PROBLEMS OF MARRIAGE AND THE FAMILY

In Beverlin v. Beverlin, 29 W. Va., 736, the judge says, "I have been unable to find any case in which the courts of Virginia or this state have ever held that a common-law marriage was held valid;" and this, he adds, is "persuasive evidence" that it is not. In Colston v. Quander (1877), 1 Va. Decisions (not officially reported), license is declared not essential; but in this case there was a formal celebration. On the probable position of the states which have not decided see Cook, The Mar. Cel. in the U. S., 525, 526.