Palimony Comes Under The Statute of Frauds

Palimony Comes Under The Statute of Frauds

June 14, 2012

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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