Does a federal court have concerns that the relationship between the husband and wife is irrevocably damaged?

2 The district court's concerns would be more compelling in a case where the couple still regularly or occasionally cohabited, but where the government contended that the marital relationship had irrevocably deteriorated. It might well be burdensome for a district court to consider such a dilemma--more properly brought to the family court--and indeed most of the cases the Carters have cited arose in this context. See United States v. Sims, 755 F.2d 1239, 1243 n. 3 (6th Cir.1985) (eschewing inquiry into the relations of cohabiting spouses); In Re Malfitano, 633 F.2d 276, 279 (3d Cir.1980) (same); see generally Note, supra, at 1566 (discussing the courts' avoidance of such analyses). This dilemma does not arise in the case of the Carters, however, who had lived apart for some time and whose permanent and irrevocable separation is clear from the record.