In re Marriage of Allen

Husband and wife were married for less than 7 months when they cross-petitioned for dissolution of marriage. Shortly before trial, wife sought to amend petition with common law claims based on 13 pre-marital years of cohabitation. Given legislature's ongoing ban on common law marriage, court was within its discretion in denying wife's motion, refusing wife's offer of proof, and in awarding property and maintenance, upon entry of judgment of dissolution, on basis of brief marriage. Parties had option to marry at any point during 13 years preceding their wedding. (GORDON and REYES, concurring.)