A purported widow will not receive death benefits after the Commonwealth Court determined that her ceremonial marriage performed in Wyoming could not be grandfathered in as a common-law marriage in Pennsylvania.

In a reported opinion in Cooney v. Workers’ Compensation Appeal Board, a three-judge panel of the Commonwealth Court held that the state could not recognize a claimant’s relationship as a common-law marriage because Wyoming did not recognize common-law marriages when the couple exchanged rings and the couple did not move to Pennsylvania until after the state stopped recognizing common-law marriages. The decision, issued June 12, affirmed a ruling from the Workers’ Compensation Appeal Board.

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