Also known as:relationships of some permanency · permanent relationship · permanency relationship · stable relationship · domestic partnership · cohabitation
Written by attorneys · grounded in primary & secondary sources — see below
A standard used in family law to describe cohabitation between unmarried persons that demonstrates stability and continuity rather than transience. Courts apply the standard to determine whether the arrangement is sufficiently settled to trigger consequences such as termination of alimony.
Sources & Authorities
How it applies
Common Examples
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Alimony Recipient's Stable Arrangement
Rhea Reynolds began living with Ronald Reed in her home after her divorce. They shared household expenses for over a year, maintained a joint bank account, and presented themselves as a couple to neighbors and family. When her former spouse sought to end alimony, the court found the arrangement met the required threshold because the cohabitation exhibited ongoing stability.
Cohabitants Agreement Breach Claim
Rita Russell and Raphael Rivera entered an oral agreement to share living costs while residing together. After eighteen months of continuous cohabitation with shared finances and mutual caregiving, Rivera moved out without notice. Russell filed a breach claim that accrued upon termination because the relationship had the necessary continuity to support enforcement of the agreement.
Select any source to read its text and confirm it supports the definition.
Uniform Acts
Model Codes
Common Law
Restatements
Casebooks
Property Division After Long Cohabitation
Regina Robinson and Roger Ramirez lived together for five years, pooling resources to purchase a home and presenting themselves publicly as partners. When the relationship ended, Robinson sought equitable division of assets acquired during the period. The court treated the arrangement as one of sufficient permanency to recognize implied agreements arising from their shared domestic life.
Marvin v. Marvin557 P.2d 106 (Cal. 1976)
Bigamy Prosecution and Cohabitation
Ronald Reed began living with Rita Russell after separating from his prior partner. They shared a home, expenses, and presented as a couple for two years. When authorities examined whether the cohabitation met the permanency threshold for related offenses, the duration and continuity satisfied the standard.
Williams v. North Carolina317 U.S. at page 297
Interracial Marriage Recognition
Raphael Rivera and Rhea Reynolds, an interracial couple, began cohabiting after moving to a new state. They maintained a household, shared finances, and raised children together for several years. The sustained domestic life confirmed the relationship's permanence under the applicable standard.
Loving v. Virginia388 U.S. 1 (1967)
Support Obligation After Separation
Roger Ramirez lived with Regina Robinson and her child for ten months, sharing expenses and providing daily care. After accepting a job elsewhere, he relocated without further contact. Robinson later relied on the prior period of stable cohabitation to establish the necessary continuity for jurisdictional purposes.
Turner v. Rogers564 U.S. 431 (2011)
Common questions
Frequently Asked
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How long must cohabitation last to qualify as a relationship of some permanency?+
No fixed duration is required. Courts examine whether the arrangement shows stability through shared finances, joint accounts, public presentation as a couple, and continuous residence rather than a transient stay.
Supporting sources
Does a relationship of some permanency require the parties to hold themselves out as married?+
Holding out as spouses strengthens the finding but is not always essential. Evidence of shared household responsibilities and financial interdependence can suffice when the cohabitation is ongoing and settled.
Supporting sources
Can temporary or seasonal cohabitation meet the standard?+
Purely transient arrangements tied to short-term employment or visits usually fall short. Extended periods of shared living, even if initially employment-related, can satisfy the standard when daily life integrates the parties over months.
Supporting sources
431 U.S. 494, 503 (1977)Property
…relatives, principally the spouse and unmarried and dependent children. Excluded from the definition of "family," and hence from cohabitation, are various persons related by blood or adoption to the head of the household. The obvious purpose of the city is the traditional one of preserving certain areas as family residential…