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Same-sex couples, for example, might not present themselves as married publicly out of fear of discrimination, and that lack of a public presentation should not necessarily count against a claim common-law marriage, said Shelly Skeen, senior attorney at Lambda Legal, a nonprofit organization that works to advance LGBTQ rights. Colorado is one of only nine states that still recognize common-law marriage, and the Colorado Supreme Court is the first high court in the country to set out a modernized standard for same-sex common-law marriage, said Cathy Sakimura, deputy director of the National Center for Lesbian Rights. The justices also recognized, as was widely expected, that same-sex couples could be in legitimate common-law marriages even before same-sex marriage was legalized in the United States in The Supreme Court justices noted that some licensed marriages, if scrutinized under the standard for establishing a common-law marriage, would fall short.

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