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Domestic Relations: Dissolution-Extraterritorial Common Law Marriage
Staff Report//July 9, 2026//
Defendant appealed the trial court’s dismissal of the petition for dissolution of a Colorado common law marriage. The trial court ruled that it lacked subject matter jurisdiction over the petition.
Although the parties disputed whether they had a valid marriage to dissolve, that factual dispute did not affect the trial court’s subject matter jurisdiction to hear a petition for dissolution.
Judgment is reversed and remanded.
S.J.M. v. T.J.F. (MLW No. 85064/Case No. ED113863 – 4 pages) (Missouri Court of Appeals, Eastern District, Torbitzky, J.) Appealed from circuit court, Cape Girardeau County, Koester, J. (Darryl Ann Jenkins and Jonathan D. Marks for appellant) (Stephen R. Southard and Lindsey A. Chamness for respondent)
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