Before 2010, palimony agreements, including those that were made orally, were enforceable under New Jersey common law. However, the New Jersey Legislature amended the state's Statute of Frauds and required palimony agreements to be in writing and with the advice of counsel. Recently, the Supreme Court of New Jersey issued a decision in Moynihan v. Lynch, No. A-64-20, 085157 (N.J.S.Ct. March 8, 2022), after granting certification from the Appellate Division to determine the constitutionality of the requirement for both parties to a palimony agreement to have the advice of independent counsel.