The Complaint's allegations indicate Plaintiff and Defendant never participated in a solemnized marriage ceremony, as required by ORS 106.010, 106.150(1). Therefore, and because Oregon does not recognize common-law marriage, Huard v. McTeigh, 113 Or. 279, 295–296, 232 P. 658, 663 (1925) ; Johnston v. Georgia – Pac. Corp., 35 Or.App. 231, 233, 581 P.2d 108, 109 (1978), Plaintiff would not be considered a “wife” or a “spouse” under Oregon law. At most she would be a common-law “domestic partner” which would entitle her to a distribution of property according to the parties' express or implied intent, which may, under certain circumstances, require distribution according to equitable principles.

The Complaint's allegations indicate Plaintiff and Defendant never participated in a solemnized marriage ceremony, as required by ORS 106.010, 106.150(1). Therefore, and because Oregon does not recognize common-law marriage, Huard v. McTeigh, 113 Or. 279, 295-296, 232 P. 658, 663 (1925); Johnston v. Georgia-Pac. Corp., 35 Or. App. 231, 233, 581 P.2d 108, 109 (1978), Plaintiff would not be considered a "wife" or a "spouse" under Oregon law. At most she would be a common-law "domestic partner" which would entitle her to a distribution of property according to the parties' express or implied intent, which may, under certain circumstances, require distribution according to equitable principles.