A "feme sole" had the right to own property and make contracts in her own name, while a "feme covert" was not recognized as having legal rights and obligations distinct from those of her husband in most respects. Instead, through marriage a woman's existence was incorporated into that of her husband, so that she had very few recognized individual rights of her own. As expressed in Hugo Black's dissent in "United States v. Yazell", "This rule 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. In certain cases, a wife did not have individual legal liability for her misdeeds since it was legally assumed that she was acting under the orders of her husband, and generally a husband and a wife were not allowed to testify either for or against each other.