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).
Still, despite the vast common law establishing palimony as a valid cause of action, such agreements were not codified until 2010, when the N.J. Legislature amended the statute of frauds to require agreements for future support between unmarried adults to be in writing and reviewed by independent counsel to each party. N.J.S.A. 25:1-5(h).
History and Evolution of Palimony Claims
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