context: However, an express agreement is not required. An implied agreement may support a common law marriage where one party intends present marriage and the conduct of the other party reflects the- same intent.
citation_a.signal: no signal
citation_a.identifier: 77 N.W.2d 479, 480
citation_a.parenthetical: cohabitation, as well as conduct and general community reputation, can be used to strengthen proof of present intent and agreement to be married
citation_a.sentence: Id.; Gammelgaard v. Gammelgaard, 247 Iowa 979, 980, 77 N.W.2d 479, 480 (1956) (cohabitation, as well as conduct and general community reputation, can be used to strengthen proof of present intent and agreement to be married), The present-intent-to-be-married requirement precludes a common law marriage based on an intent to be married at some future time.
citation_b.signal: see
citation_b.identifier: 215 Iowa 1287, 1289-90
citation_b.parenthetical: agreement to live as husband and wife until lawfully married does not establish present intent to enter into marriage relationship
citation_b.sentence: See State v. Grimes, 215 Iowa 1287, 1289-90, 247 N.W. 664, 665 (1933) (agreement to live as husband and wife until lawfully married does not establish present intent to enter into marriage relationship).