[Red Steel]

I don't know for sure I think the term 'common law wife or marriage' was something that made it's appearance in the 70s.

If so, common law generally requires more than co-habitation from time to time.

I usually think of co-habitations for certain period of time being together as common in law marriages ...set by state statutes. What went for marriages in Kenya in 1960 I have no idea. Could a previous Kenyan common in law marriage be recognized in US courts which could overturn a marriage sanctioned by a US state?

[Vendome]

That is what I thought. It was developed in the 70’s.

[Lurking Libertarian]

I don't know for sure I think the term 'common law wife or marriage' was something that made it's appearance in the 70s.

It's a much older legal phrase. Most states abolished common law marriage in the 1920s or 30s.

[Lurking Libertarian]

More info here.