For years, when Kevin Brown asked her to marry him, Diane Miller would reply that a marriage certificate was "just a piece of paper."

She might see things differently now.

Her lack of a marriage certificate, or any proof that the couple entered into even a common law marriage, has sunk her attempt to divorce Brown and hit him up for alimony.

That's how a Susquehanna County judge saw the case, and a state Superior Court panel backed him up this week, by dismissing Miller's appeal of the dismissal of her divorce complaint.

In essence, state Judge Carl A. Solano observed, the dispute came down to just a few little words.

Pennsylvania has not allowed common law marriage since January 2005, but it does recognize such non-traditional unions that were properly entered into before that date.

However, for a pre-2005 common-law marriage to be valid, the partners must have jointly uttered words constituting an oral contract of marriage. They had to express their mutual desire to be husband and wife.

To Miller's misfortune, there is no evidence such words were exchanged during the 22 years she and Brown were a couple, Solano found.

He noted that Miller and Brown began a romantic relationship in May 1994 and within months were living together. In 1995, while Brown was still legally married to someone else, Miller gave birth to their only child.

The two eventually began introducing themselves as spouses, until in 2016 Miller filed for divorce.

That's when the importance of that piece of paper kicked in. County President Judge Jason J. Legg dismissed Miller's divorce complaint, finding she had provided no proof that she was wed to Brown in any legally recognized manner.

Legg rejected Miller's argument that a document Brown had signed listing her as his wife to obtain health insurance coverage from his employer, the Pennsylvania Department of Transportation, provided evidence of matrimony.

The county judge reached the same conclusion when Miller provided a consent of spouse form she signed so Brown could withdraw some of his retirement benefits, and when she pointed out that the couple had stated they were married in filing their federal tax return in 2015.

Brown testified that he identified Miller as his wife only to get the health insurance coverage. He said he asked Miller to marry him several times over the course of their relationship, but she refused.

Miller admitted the couple never exchanged common law vows, but insisted she never flat-out refused to marry Brown, Solano noted.

Solano cited a state Supreme Court edict that a common law marriage "can only be created by an exchange of words in the present tense, spoken with the specific purpose that the legal relationship of husband and wife is created."

"Miller herself testified that no such exchange of words occurred," Solano wrote. Legg "therefore was correct not to consider co-habitation or reputation evidence and to conclude that there was insufficient evidence of the marriage."