In Braddock v. Taylor, 592 S.W.2d 40, 42 (Tex. Civ. App.--Beaumont 1979, writ ref'd n.r.e.), the question was whether decedent David Taylor was married to appellee Janice Taylor at the time of his death, as the trial court held. Id. at 41. The evidence showed that decedent was previously married to someone else and not divorced when he and Janice began holding themselves out as husband and wife in Texas. Id. at 42. Decedent and Janice then moved to California, which does not recognize common-law marriages, and continued their relationship. Id. Decedent divorced his prior wife, and then he died. Id. "Since no marriage between the deceased and appellee was ever contracted or celebrated in California, nor contracted in Texas after the impediment was removed," the trial court erred by holding that Janice was decedent's wife and heir. Id.