I would object to that title for the same reasons as presented above  Splitting hairs and playing at semantics does not sidestep the above raised problems imo  And one of the arguments Tarc has alluded to is one I agree completely with If you cant describe a person in terms of their own accomplishments but only on the nature of their relationship with someone else then they simply are not notable enough for an article  If Sarah Brown is only really notable for being the spouse of someone then this article should be deeply pruned merged and redirected to Gordon Brown