Ayuso-Morales V. Sec'y HHS

Date:

Widow did not qualify for widow's Social Security benefits where she cohabitated for 20-years with her future husband in jurisdiction not recognizing "common law marriages" and married husband less than nine months before his death. Widow's status, under Puerto Rican law, as "concubine" for purpose of disposition of intestate property did not qualify her as "widow" entitled to receive Social Security benefits.