Daniel v. Daniel
Daniel v. Daniel, 2025 UT App 193 (Tenney, J.)
Family Law
The Utah Court of Appeals held:
- The district court did not commit reversible error with respect to its rejection of Wife’s petition for the establishment of an unsolemnized marriage.
- Judicial tip: The parties to an unsolemnized marriage must mutually consent to the establishment of the marriage.
- Practice tip: The Court of Appeals opined that it is at least possible that the language in Whyte v. Blair, 885 P.2d 791, 794 (Utah 1994), suggests consent could be in reference to “something more like a marriage-like relationship in the absence of any discussion of marriage itself.”