Crowe v. De Gioia

In Kozlowski v. Kozlowski, 80 N.J. 378 (1979), we recognized the possible existence of an agreement between consenting adults who desire to live together. However, Judge Halpern, writing for the Court, carefully noted that “our decision today has not judicially revived a form of common law marriage which has been proscribed in New Jersey since 1939 by N.J.S.A. 37:1-10.” Id. at 387. He also observed: “Alimony may be awarded only in actions for divorce or nullity, and equitable distribution is awarded only in actions for divorce. N.J.S.A. 2A:34-23 et seq.” Id. at 383. Today’s decision, only…