TN 8 (12-15)

PR 05830.010 District of Columbia

A. PR 15-197 Validity of Civil Partnerships and Same-Sex Marriages Performed in England and Wales Under District of Columbia Law—Life Case

Date: April 29, 2015

1. Syllabus

The claimant and number holder (NH) are not considered validly married under Title II of the Act. However, the agency can deem the couple as married for Title II benefit purposes. The claimant and NH entered into a civil partnership August 2008 in London, England. The NH continues to reside in England and the claimant filed for benefits on the NH’s record July 2013. Since the NH is domiciled in England at the time the application is filed, we apply the law of the District of Columbia to determine whether the couple was validly married. Under the law of the District of Columbia, the validity of a marriage is determined by the law of the jurisdiction.

The couple is not considered validly married under English law because there is no allegations or evidence that a same-sex marriage occurred between the claimant and the NH nor are there any allegations that their civil partnership was converted to a marriage. However, the civil partnership provides the claimant the same status as a spouse of the NH under English intestacy law. Therefore, the agency can deem the claimant and the NH as married on this basis and the agency should find that the claimant is entitled to spouse’s benefits on the NH’s record.

2. Opinion

QUESTION PRESENTED

Whether P~, the claimant, and N~, the number holder (NH), who entered into a civil partnership on August XX, 2008, in London, England are validly married for purposes of determining claimant’s entitlement to Title II benefits as the NH’s spouse under the Social Security Act (Act)? If they cannot be considered validly married, can the Agency deem the couple as married for purposes of determining claimant’s entitlement to Title II benefits as the NH’s spouse?

OPINION

No, the claimant and the NH are not validly married under Title II of the Act. However, yes, the agency can deem the couple as married for Title II benefit purposes. The civil partnership provides the claimant the same status as a spouse of the NH under English intestacy law. Thus, the agency can deem the claimant and the NH as married on this basis. Accordingly, if the claimant meets the other criteria for entitlement to spouse’s benefits, the agency should find that the claimant is entitled to spouse’s benefits on the NH’s record.

BACKGROUND

The claimant and the NH entered into a civil partnership on August XX, 2008, in London, England. The NH continues to reside in England. On July XX, 2013, the claimant filed for Social Security benefits on the NH’s record. You requested a legal opinion regarding whether the claimant is entitled to Title II spouse’s benefits on the record of the NH.

ANALYSIS1

To be entitled to spouse’s benefits under the Social Security Act (Act), a claimant must show, among other things, that he or she is the “husband” or “wife” of an insured NH.2 See 42 U.S.C. §§ 402(b), (c), 416(a)(1); 20 C.F.R. § 404.330. As pertinent here, the Act provides two methods for a claimant to show that he or she is the husband or wife of an insured who is domiciled outside the United States. First, a claimant is the husband or wife of such insured if, among other things, the courts of the District of Columbia would find that the claimant was validly married to the insured at the time he or she applied for benefits. See 42 U.S.C. § 416(h)(1)(A)(i); 20 C.F.R. § 404.345. Second, even if a claimant was not validly married to such insured at the time he or she applied for benefits, he or she will be deemed to be the insured’s husband or wife if, under the law applied by the courts of the District of Columbia in determining the devolution of intestate personal property, he or she would have the “same status” as a husband or wife of the insured with respect to the taking of such property. See 42 U.S.C. § 416(h)(1)(A)(ii); 20 C.F.R. § 404.345.

The claimant bears the burden of proving that he or she is in a valid marital relationship with the insured and is therefore the insured’s spouse. See 20 C.F.R §§ 20 C.F.R. §§ 404.345, 404.704, 404.723, 404.725. In determining the claimant’s relationship as the insured’s spouse, the agency looks to the law of the state where the insured had a permanent home at the time the claimant applied for benefits. See 42 U.S.C. § 416(h)(1)(A)(i). If the insured was not domiciled in any state, the agency applies the law of the District of Columbia. See 42 U.S.C. § 416(h)(1)(A)(i); 20 C.F.R. § 404.345; POMS GN 00210.006(B)(2).a.

Validity of Same-Sex Marriage Under the Law of the District of Columbia

Here, because the NH resided in England at the time the claimant applied for benefits, we apply District of Columbia law to determine whether the couple was validly married. Under the law of the District of Columbia, the validity of a marriage is determined by the law of the jurisdiction where the marriage was entered into. See McConnell v. McConnell, 99 F. Supp. 493, 494 (D.D.C. 1951); Carr v. Varr, 82 F. Supp. 398 (D.D.C. 1949); Gerardi v. Gerardi, 69 F. Supp. 296 (D.D.C. 1946). The only exception is when the marriage is in violation of strong public policy of the District of Columbia. Hitchens v. Hitchens, 47 F. Supp. 73, 74 (D.D.C. 1942). As pertinent here, the District of Columbia began recognizing as valid same-sex marriages entered into in other jurisdictions beginning on July 7, 2009.3 See Section 1287a of the Jury and Marriage Amendment Act of 2009, D.C. Code § 46-405.01 (“A marriage legally entered into in another jurisdiction between 2 persons of the same sex that is recognized as valid in that jurisdiction, that is not expressly prohibited . . . , and has not been deemed illegal . . . , shall be recognized as a marriage in the District.”). Accordingly, the recognition of same-sex marriages performed in other jurisdictions does not appear to violate a strong public policy of the District. Therefore, we next must examine the validity of same-sex marriage under the law of England and Wales.

The Claimant is not Validly Married to the NH Under English Law

The government of England and Wales introduced the Marriage (Same Sex Couples) Act 2013.4 This Act came into force on March 13, 2014, and allows same-sex couples to enter into a marriage in accordance with the Marriage Act 1949,5 bestowing on them the same legal rights as heterosexual couples, but preserves the Canon Law of the Church of England by not requiring Churches of England to apply the new law.6 Beginning December 10, 2014, same-sex partners have the option of converting their partnerships into marriages.7 In cases where a civil partnership is converted into a marriage, the effect of the conversion is to end the civil partnership and create a resulting marriage. The marriage is “to be treated as having subsisted since the date the civil partnership was formed”8 The law providing for Civil Partnerships will continue, and there are no requirements compelling civil partners to change their partnerships into a marriage. In the claim at issue, there are no allegations or evidence that a same-sex marriage occurred between the claimant and the NH. Nor are there any allegations that the civil partnership the couple entered into was converted to a marriage. Accordingly, the couple is not validly married under English Law.

The Claimant has the Same Status as a Husband of the NH Under English Intestacy Law

If the claimant is not validly married to NH, the agency will deemed the couple to be married, if, under the law applied by the courts of the District of Columbia in determining the devolution of intestate personal property, the claimant would have the “same status” as a husband of the NH with respect to the taking of such property, if the NH were to die. See 42 U.S.C

§ 46(h)(1)(A)(ii); 20 C.F.R. § 404.345. Under District of Columbia law, intestate inheritance rights are determined by the law of the decedent’s domicile. Javier v. Comm’r of Soc. Sec., 407 F.3d 1244, 1247 (D.D.C. 2005) (citing In re Gray’s Estate, 168 F. Supp. 124 (D.D.C. 1958)). Here, the NH is domiciled in England. Accordingly, to determine whether the claimant would have the requisite status with respect to inheritance of the NH’s intestate property, we apply English law.

England and Wales enacted the law providing for civil partnerships in 2004, which entered into effect on December 5, 2005.9 Entering into a civil partnership creates the same legal relationship between partners as a marriage between a husband and wife, but with the different terminology of “civil partners.” Section 71 of the Civil Partnership Act amended a number of provisions relating to wills and the administration of estates so that they apply in the same way to civil partnerships and married couples.10 If a civil partner dies intestate, the same rules apply to the surviving civil partner as would apply in marriage to a surviving spouse.11 Section 46 of the Administration of Estates Act 1925 provides that if a civil partner dies intestate without issue, the surviving civil partner inherits the residual estate absolutely.12

A civil partnership becomes legal when the civil partnership registration certificate is signed by both parties. Once formed, a civil partnership only ceases upon death, dissolution, or annulment.13 Civil partnerships must be registered with the Registrar General,14 who is required by law to maintain a register of civil partnerships and any decrees of dissolution or nullity of these partnerships.15 A certificate showing proof of the civil partnership are available for a small fee after the ceremony, and copies may be obtained from the Registrar General’s Office at a later date for an additional fee.16

Here, the claimant has presented SSA with a certified copy of an Entry of Civil Partnership, registered on August XX, 2008. The document is signed by both the claimant and the NH. In addition, the law of England and Wales provides that if a civil partner dies intestate, the same inheritance rights apply to the surviving civil partner as would apply in marriage to a surviving spouse. Based on these facts, it appears that the claimant qualifies as an individual entitled to inherit a husband’s share of the NH’s intestate property under the law of England and Wales and accordingly, the agency would deem the couple as married.

CONCLUSION

Although the claimant’s relationship with the NH would not be recognized as a valid marriage under the law of England and Wales, the claimant has the same status as a husband of the NH under the law of England and Wales. Thus the agency can deem the couple married for Title II purposes.

B. PR 15-192 A Same-Sex Marriage-Like Relationship in British Columbia, Canada

Date: September 14, 2015

1. Syllabus

Since the number holder (NH) was domiciled in British Columbia, Canada at the time of his death, we apply the laws that the District of Columbia courts would apply to determine whether a valid marriage existed at the time of the NH’s death. Under the law of the District of Columbia, the validity of a marriage is determined by the law of the jurisdiction where the marriage was entered into (the law of British Columbia, Canada).

There is no allegation that a common-law or ceremonial same-sex marriage occurred between the claimant and the NH. Therefore, if the claimant cannot be entitled to widower’s benefits based on a marriage to the NH, the claimant may be deemed to be the widower in determining the devolution of intestate personal property in which the claimant would have the same status as a widower of the NH with respect to taking of such property. In this case, the NH and claimant had a “marriage-like” relationship for 23 years (more than 2 year requirement), which under the law of British Columbia, would give the claimant the “same status” as a widower of the NH with respect to inheritance of the NH’s intestate personal property. Therefore, the agency can find that the couple satisfies the relationship requirement for purposes of Social Security widower’s benefits.

2. Opinion

QUESTION PRESENTED

Whether two residents of British Columbia, Canada, satisfy the relationship requirement for purposes of widower’s benefits based on a marriage-like relationship.

SHORT ANSWER

Yes. In this case, because the claimant and the number holder (NH) lived with each other in a marriage-like relationship for longer than two years, the agency can find that they satisfy the relationship requirement for purposes of Social Security widower’s benefits.

SUMMARY OF EVIDENCE

The claimant, J~, filed for widower’s benefits and the lump sum death payment on the record of the NH, B~. As part of the claim, the claimant completed a Statement of Marital Relationship form over the telephone. According to the claimant, he was in a same-sex, marriage-like relationship with the NH since January 1990. They lived together in N~, British Columbia, Canada for over twenty-three years. They never married but held themselves out as “life partners” with the understanding that they would live together forever. The NH died on September XX, XXXX.

As evidence of their relationship, the claimant has submitted a variety of illustrative documents:

· Canadian 2012 tax return summary estimate for 2013;

· Canadian T3 trust income tax and information return for the W~ Family Trusts for 2003;

· Last Will and Testament of NH dated February XX, XXXX;

· Power of Attorney for NH dated February XX, XXXX, appointing claimant as NH’s primary representative;

· State of Title Certificate for claimant and NH issued in June 2002;

· The 2004 Rural Property Tax Notice issued to claimant and NH;

· Joint financial account from TD Canada Trust as of May XX, XXXX, and May XX, XXXX; and

· Joint TD Waterhouse account as of November XX, XXXX and May XX, XXXX.

ANALYSIS

I. Law Concerning Same-Sex Marriages

Generally, an individual is entitled to widow’s or widower’s benefits if that individual (1) is the insured’s widow or widower and the marital relationship lasted at least nine months before the insured died; (2) files an application; (3) is at least 60 years old; (4) is not entitled to an old-age benefit that is equal to or larger than the insured person’s primary insurance amount; and (5) is not currently married. Sections 202(e), 202(f) of the Act; 20 C.F.R. § 404.335. Similarly, upon the death of a person who died as a fully or currently insured individual under the Act, a lump-sum death payment may be paid to the widow or widower of the insured who was living in the same household at the time of death. Section 202(i) of the Act; 20 C.F.R. § 404.391.

Here, at the time of the NH’s death, the NH was domiciled in British Columbia, Canada. Because the NH was not domiciled in the United States when he died, we apply the laws that the District of Columbia courts would apply to determine whether a valid marriage existed at the time of the NH’s death. See section 216(h)(1)(A)(i) of the Act; 20 C.F.R. § 404.345, POMS GN 00210.066B.2.a. See section 216(h)(1)(A)(i) of the Act; 20 C.F.R. § 404.345, POMS GN 00210.006(B)(2). Under the law of the District of Columbia, the validity of a marriage is determined by the law of the jurisdiction where the marriage was entered into. See McConnell v. McConnell, 99 F. Supp. 493, 494 (D.D.C. 1951); Carr v. Varr, 82 F. Supp. 398 (D.D.C. 1949); Gerardi v. Gerardi, 69 F. Supp. 296 (D.D.C. 1946). The only exception is when the marriage is in violation of strong public policy of the District of Columbia. Hitchens v. Hitchens, 47 F. Supp. 73, 74 (D.D.C. 1942).

As pertinent here, the District of Columbia began formally recognizing the validity of same-sex marriages entered into in other jurisdictions beginning on July 7, 2009. See Section 1287a of the Jury and Marriage Amendment Act of 2009, D.C. Code § 46-405.01 (“A marriage legally entered into in another jurisdiction between 2 persons of the same sex that is recognized as valid in that jurisdiction, that is not expressly prohibited . . . , and has not been deemed illegal . . . , shall be recognized as a marriage in the District.”). Accordingly, it is clear that from July 7, 2009, the recognition of same-sex marriages performed in other jurisdictions does not appear to violate a strong public policy of the District of Columbia.

Same-sex marriages have been valid in British Columbia, Canada, since May 1, 2003, when the British Columbia Court of Appeal recognized same-sex marriage but suspended its decision until “July 12, 2004, solely to give the federal and provincial governments time to review and revise legislation to accord with this decision.” Barbeau v. British Columbia (Attorney General), [2003] B.C.C.A., 251, para. 7. However, on July 8, 2003, the Court lifted the suspension, giving full effect to its decision. Barbeau v. British Columbia, [2003] B.C.C.A., 406. Thus, same-sex marriages became legal in British Columbia at least as of July 8, 2003.

Furthermore, on July 20, 2005, the Civil Marriage Act legalized same-sex marriage across Canada by defining marriage as “the lawful union of two persons to the exclusion of all others,” and instructing that “a marriage is not void or voidable by reason only that the spouses are of the same sex.” Civil Marriage Act, S.C. 2005, c. 3, § 4 (Can.).

However, here there is no allegation that a common-law or ceremonial same-sex marriage occurred between the claimant and the NH.

II. Law Concerning Other Types of Same-Sex Relationships

If the claimant cannot be entitled to widower’s benefits based on a marriage to the NH, the claimant may nevertheless be deemed to be the widower, if, under the law applied by the courts of the District of Columbia in determining the devolution of intestate personal property, the claimant would have the “same status” as a widower of the NH with respect to the taking of such property, if the NH were to die. See § 216(h)(1)(A)(ii); 20 C.F.R. § 404.345. Under District of Columbia law, intestate inheritance rights are determined by the law of the decedent’s domicile. Javier v. Comm’r of Soc. Sec., 407 F.3d 1244, 1247 (D.D.C. 2005) (citing In re Gray’s Estate, 168 F. Supp. 124 (D.D.C. 1958)). As previously noted, the claimant and the NH lived together in British Columbia, Canada. Accordingly, to determine whether this relationship would allow the claimant to have the requisite status as a spouse with respect to inheritance of the NH’s intestate property, we apply the law of British Columbia, Canada.

British Columbia’s Estate Administration Act, and the subsequent Wills, Estates, and Succession Act, which came into force on March 31, 2014, provide the rules for intestate succession.17 The Estate Administration Act’s definition of spouse included “common law spouse,” which meant either:

(a) A person who is united to another person by a marriage that, although not a legal marriage, is valid by common law, or

(b) a person who has lived and cohabitated with another person in a marriage-like relationship, for a period of at least two years immediately before the person’s death.

Estate Administration Act, S.B.C. 1996, c. 122, pt. 1, available at

http://www.canlii.org/en/bc/laws/stat/rsbc-1996-c-122/104764/rsbc-1996-c-122.html#Part_1_General_498. The Wills, Estates and Succession Act does not refer to “common law spouse,” and instead states, “2 persons are spouses of each other for purposes of this Act if they were both alive immediately before a relevant time and (a) they were married to each other, or (b) they had lived with each other in a marriage-like relationship for at least 2 years.” Wills, Estates and Succession Act, S.B.C. 2009, c. 13, pt. 2, available at

http://www.bclaws.ca/civix/document/id/complete/statreg/09013_01#section2.

The expression “marriage-like relationship” is found in a number of British Columbia’s statutes that deal with the rights and obligations of unmarried couples. British Columbia’s Court of Appeal has held that the expression should be interpreted the same across statutes in “all cases where it is used to describe the status of two persons who have chosen to live together in a certain way.” Austin v. Goerz (2007) 74 B.C.L.R. 4th 39, para. 32 (Can. B.C. C.A.), available at https://www.canlii.org/en/bc/bcca/doc/2007/2007bcca586/2007bcca586.html?searchUrlHash=AAAAAQA0bWFycmlhZ2UtbGlrZSByZWxhdGlvbnNoaXAgY29tbW9uIGxhdyBHb3N0bGluIFRha2FjcwAAAAAB.

Thus it appears that under the law of British Columbia, a partner of a NH in a “marriage-like relationship” would have the “same status” as a widower of the NH with respect to the inheritance of the NH’s intestate personal property. See § 216(h)(1)(A)(ii); 20 C.F.R. § 404.345.

The legal test for determining whether a particular relationship is “marriage-like” is whether it was the parties’ subjective intention to be in a “marriage-like relationship.” Gostlin v. Kergin (1986), 3 B.C.L.R. 2d 264, page 5 (Can. B.C. C.A.), available at https://www.canlii.org/en/bc/bcca/doc/1986/1986canlii164/1986canlii164.html. In Gostlin, the Court stated:

If each partner had been asked, at any time during the relevant period of more than two years, whether, if their partner were to be suddenly disabled for life, would they consider themselves committed to life-long financial and moral support of that partner, and the answer of both of them would have been “Yes”, then they are living together as husband and wife. If the answer would have been “No”, then they may be living together, but not as husband and wife.

Id. at 5. However, the Court notes that sometimes ascertaining intention can prove difficult in particular circumstances, in which case objective factors can be relied upon:

Did the couple refer to themselves, when talking to their friends, as husband and wife, or as spouses, or in some equivalent way that recognized a long-term commitment? Did they share the legal rights to their living accommodation? Did they share their property? Did they share their finances and their bank accounts? Did they share their vacations? In short, did they share their lives? And, perhaps most important of all, did one of them surrender financial independence and become economically dependent on the other, in accordance with a mutual arrangement?

Id. at 6.

The Court enunciated additional factors indicating a “marriage-like relationship” in Takacs v. Gallo (1998), 48 B.C.L.R. 3d 265 (Can. B.C. C.A.), available at http://www.canlii.org/en/bc/bcca/doc/1998/1998canlii6429/1998canlii6429.html. In that case, the Court held that courts must focus first on the intentions of the parties to live in a marriage-like relationship, using objective factors to divine those subjective intentions. Id. para. 53. The Court noted that although the parties may not explicitly acknowledge that a marriage-like relationship exists, “conduct speaks louder than words.” Id. para. 40.

Objective factors that may be relevant in determining the parties’ intentions are seldom determinative in and of themselves; many people who live together, and meet many of these objective criteria, do not actually intend or enter the kind of psychological and emotional union generally associated with marriage. Id. para. 55. Therefore, courts must recognize the uniqueness of each relationship and apply a flexible approach when considering the various objective criteria provided in the authorities. J.J.G. v. K.M.A. (2009), 71 R.F.L 6th 349, para. 37 (Can. B.C. S.C.), available at https://www.canlii.org/en/bc/bcsc/doc/2009/2009bcsc1056/2009bcsc1056.html.

III. The Claimant’s Application

The claimant and the NH had a marriage-like relationship that lasted for much longer than the two-year period required under the law. They lived together for more than twenty-three years and held themselves out as “life partners.” The documents the claimant submitted showed they comingled finances, jointly owned real property, and filed taxes as common-law spouses. They also created a family trust with their separate children as equal shareholders in the trust. Further, the NH named the claimant as executor and trustee of this estate upon his death, but in the event the claimant could not exercise these duties, the NH named his son and the claimant’s son to jointly act as executor and trustee. All of this evidence shows that this couple was in a marriage-like relationship and therefore were spouses for purposes of British Columbia’s law of intestate succession.

CONCLUSION

It is our opinion that under the laws of British Columbia, Canada, the claimant and the NH were in a marriage-like relationship and would be considered spouses for purposes of intestate succession. Thus, the agency can deem that the couple was married for social security purposes. Accordingly, assuming all the other eligibility requirements are met, the claimant may be entitled to benefits as the NH’s widower.


Footnotes:

[1]

We note that our discussion of the law of England is based in part on an opinion we received from the Library of Congress covering the law of two countries in the United Kingdom (UK), England and Wales. This opinion does not address the law in the UK countries of Northern Ireland and Scotland.

[2]

To be eligible for spousal benefits, the claimant must also show that he or she: (1) has been married to the insured individual for at least one year, shares a natural child with the insured, or is entitled to certain benefits in the month before the marriage; (2) has filed an application for spousal benefits; (3) has attained aged 62 or has in his or her care a child entitled to child’s benefits; and (4) is either not entitled to old-age or disability benefits, or is entitled to such benefits based on a primary insurance amount which is less than one-half of the spouse’s primary insurance amount. See 42 U.S.C. § 402(b)(c); 20 C.F.R. § 404.330. As we have not been asked to provide an opinion on whether claimant meets these additional requirements, our opinion will focus on whether the claimant and the NH are validly married or can be deemed married.

[3]

Domestic Partnerships were effective in the District on January 6, 2007. SSA can deem these domestic partnerships as marriages. See GN 00210.004.

[4]

Marriage (Same Sex Couples) 2013, c. 30, § 1, http://www.legislation.gov.uk/ukpga/2013/30/contents/enacted.

[5]

Marriage Act 1949, 12, 13 & 14 Geo. 6, c. 76, http://www.legislation.gov.uk/ukpga/Geo6/12-13-14/76/contents.

[6]

Civil Partnership Act 2004, c. 33, § 1, http://www.legislation.gov.uk/ukpga/2004/33/contents.

[7]

The Marriage of Same Sex Couples (Conversion of Civil Partnership) Regulations 2014, 3181, http://www.legislation.gov.uk/uksi/2014/3181/pdfs/uksi_20143181_en.pdf

[8]

Id .

[9]

House of Commons Library, Civil Partnerships, Standard Note SN/HA/5608, Feb. 2011.

[10]

Civil Partnership Act 2004, c. 33, §71, http://www.legislation.gov.uk/ukpga/2004/33/contents.

[11]

Succession: Intestacy: Distributions (England & Wales): Surviving Spouse or Civil Partner, IHTM12121, HM REVENUE AND CUSTOMS, http://www.hmrc.gov.uk/manuals/ihtmanual/ihtm12121.htm (last visited Aug. 26, 2014).

[12]

Administration of Estates Act 1925, 15 & 16 Geo. 5, c. 23, § 46, http://www.legislation.gov.uk/ukpga/Geo5/15-16/23/contents.

[13]

Civil Partnership Act 2004, c. 33, § 1, http://www.legislation.gov.uk/ukpga/2004/33/contents.

[14]

Id. § 2.

[15]

Id. § 30.

[16]

Order a Copy of a Birth, Death or Marriage Certificate, GOV.UK, https://www.gov.uk/order-copy-birth-death-marriage-certificate (last updated Aug. 4, 2014).

[17]

. The Wills, Estates and Succession Act was intended to provide greater certainty for individuals who put their last wishes into writing and simplify the process for those responsible for distributing an estate, but did not meaningfully change the definition of “spouse.” British Columbia, Ministry of Justice, available at http://www.ag.gov.bc.ca/legislation/wills-estates-succession-act/index.htm; Compare Estate Administration Act, S.B.C. 1996, c. 122, pt. 1 available at

http://www.canlii.org/en/bc/laws/stat/rsbc-1996-c-122/104764/rsbc-1996-c-122.html#Part_1_General_498, and Wills, Estates and Succession Act, S.B.C. 2009, c. 13, pt. 2, available at http://www.bclaws.ca/civix/document/id/complete/statreg/09013_01#section2.


To Link to this section - Use this URL:
http://policy.ssa.gov/poms.nsf/lnx/1505830010
PR 05830.010 - District of Columbia - 11/10/2015
Batch run: 12/04/2015
Rev:12/04/2015