Renshaw v. Heckler

Edith (plaintiff) and Albert Renshaw began living together on July 5, 1958, and cohabitated for 21 years, mostly in Buffalo, New York. The Renshaws did not have a formal ceremonial marriage, but they considered themselves to be married and presented themselves to friends, relatives, and the public as a married couple. Albert gave Edith a wedding band, and the Renshaws celebrated July 5 as their wedding anniversary. Edith adopted the last name Renshaw and changed her legal name on her Social Security card. The Renshaws also filed joint tax returns annually, and Albert listed Edith as his wife and beneficiary on his life insurance. The Renshaws had one child together. On eight occasions between 1968 and 1975, the Renshaws drove from Buffalo to visit relatives in Virginia and North Carolina, stopping overnight each way at the Port Motel in Pennsylvania. Albert presented Edith as his wife to the motel and to everyone he knew in Pennsylvania. Following Albert’s death, Edith sought widow’s insurance benefits from Social Security and was denied. Edith filed suit in the district court against the Secretary of the United States Department of Health and Human Services, Margaret Heckler, (secretary) (defendant) and the district court denied her claim, finding the Renshaws did not have a valid common-law marriage under Pennsylvania law. Edith appealed.