The Washington decisions have settled beyond a doubt that a valid marriage can not take place in this state in any manner other than that prescribed by statute. The statutes were originally enacted in 1854 and have come down to us with practically no alterations and with but few additions. As early as 1892 it was decided that the statutory requirements were mandatory, that a ceremony was essential and that common law marriages, in this state, were invalid. Thus the substantive law has become fixed.
Burton J. Wheelon,
Notes and Comments,
The Evidential Force of Habit and Repute as Opposed to the Substantive Law Concerning Marriage,
1 Wash. L. Rev.
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