" Similarly, in the case of Crockett v. Consolidated Paper Co, 281 Mich. 571 (1937), the plaintiff claimed to be the common-law wife of a workman employed by the defendant. Plaintiff had been married to a Mr. Willis in the State of Georgia.

In other cases the prior marriage was not terminated before the death of the bigamous husband; the contests were between competing wives — here only one woman, Ila, claims to be Stevenson's widow. In Crockett v. Consolidated Paper Co, 281 Mich. 571 (1937), it was the claimant who had been sloppy about obtaining a divorce before marrying again, not a woman like Ila who entered into the second marriage in good faith unaware that there was a prior undissolved marriage. Also in Crockett the defendant's liability arose only if the husband left a widow — while here the city must pay someone, either Stevenson's brother or the woman Stevenson purported to marry.

See Seibly v. Circuit Judge (1895), 105 Mich. 584, 586; Heck v. Bailey (1918), 204 Mich. 54; Wilson v. Wilson (1889), 73 Mich. 620. See, also, Crockett v. Consolidated Paper Co. (1937), 281 Mich. 571; contrast Hess v. Pettigrew (1933), 261 Mich. 618. See, generally, 24 Am Jur 2d, Divorce and Separation, § 435, p 559.

That case is much stronger than the one under consideration, for that case involved a couple that were known as husband and wife, while in the present one, there is not any evidence that they held themselves out to the community as husband and wife, neither is there evidence of an agreement of a contract. The case of Crockett v. Consolidated Paper Co. (1937), 281 Mich. 571, 275 N.W. 253, involved a case where a man and woman were living together illicitly, such a relation continued illicit and the court held that such relation continued illicit although the woman claimed a secret common-law marriage. The court further held that common-law marriage required publicity, and, therefore, the woman was not related to the man so as to be entitled to claim compensation for his death.