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dissent in United States v. Yazell, "This rule [coverture] has worked out in reality to mean that though the husband and wife are one, the one is the husband." A married woman could not own property, sign legal documents or enter into a contract, obtain an education against her husband's wishes, or keep a salary for herself. If a wife was permitted to work, under the laws of coverture, she was required to relinquish her wages to her husband. A feme couvert could not be sued or sue in her own name.

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