The New Jersey Supreme Court first established “palimony,” or support paid from one unmarried cohabitant to another, as a cognizable cause of action in 1979.Kozlowski v. Kozlowski, 80 N.J. 378 (1979). In the more than 30 years that followed, our courts consistently recognized a broad range of cohabitation agreements, most typically agreements for future support and/or distribution of property acquired by the parties — express and implied, oral and written — as valid, enforceable contracts. See,e. g., Crowe v. DeGioia, 90 N.J. 126, 129 (1982); In the Matter of the Estate of Roccamonte, 174 N.J. 381 (2002); Houseman v. Dare, 405 N.J. Super. 538 (App. Div. 2009).
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