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As a rule of thumb, relatives of famous people are not inherently notable. This is especially true of children but can also be true of spouses. To have an article, she needs to be notable in her own right. —C.Fred (talk) 22:00, 31 October 2007 (UTC)[reply]
I tend to agree with Asterisk. I haven't seen anything that makes Sessions notable by herself. (See wp:NOTINHERITED). She is not notable except for being the wife of Joseph Smith. Even the Current wives don't have their own pages (Frances Beverly Johnson is a redirect to Thomas S. Monson)