• Alaska has recognized palimony based upon principles of contract. • Arizona recognizes palimony, and has awarded palimony. The awarding of palimony in Arizona is "rare" however. Most recent pro-palimony literature/case: (1986) • California recognizes palimony, and has awarded palimony. California may also award property palimony due to "oral contracts." California has been listed as one of the three most "liberal" palimony laws, in addition to Washington State and Minnesota. Most recent pro-palimony literature/case: (2010) • Colorado recognizes palimony. Most recent pro-palimony literature/case: (2012) • Delaware: No anti-palimony law exists in Delaware, but no literature could be found in regards to successful palimony lawsuits in Delaware. Most recent pro-palimony literature/case (none) • Florida does not recognize palimony rights. • Hawaii recognizes palimony, and has awarded palimony. • Illinois- Although Illinois is generally considered to be a state that does not recognize palimony, that appears to be changing. "The Appellate Court of Illinois has found that a state court judge who is a physician’s former same-sex partner can assert an unjust enrichment legal claim — that is, a palimony claim — to seek compensation for her financial contributions toward both the home they shared and the physician's professional practice." • Iowa will recognize palimony if common-law marriage is proven. • Maryland- While palimony actions are not permitted in Maryland, Maryland recognizes certain types of palimony-type actions. For example, if evidence that a promise to marry a pregnant individual has been breached, "damages" may be awarded. Also, "oral contracts" may be used to divide property (see previous citation). • Minnesota- In 1980, Minnesota passed two statutes nicknamed the "anti-palimony statutes." These require written contracts in order to award palimony for a cohabiting plaintiff. However, if a cohabiting partner "believes" that they are married, then they are referred to as a "Putative Spouse", which would give them the same rights as a legally married person in a divorce proceeding. Minnesota has been listed as one of the three most "liberal" palimony states, in addition to Washington State and California. New Mexico also recognizes the right to palimony when couples that qualified for common law marriage in another state move to New Mexico, but New Mexico itself does not recognize common law marriage from its own state. • New York- Obtaining palimony in New York is a "daunting task". Also, "oral contracts that are vague or indefinite will not pass muster." But another legal website states that if there was an "oral agreement," there may still be a case. • North Carolina will generally enforce "implied contracts" between unmarried couples. • North Dakota- Very little information in regard to palimony in North Dakota is available online. However, palimony attorneys are located in North Dakota. • Ohio- "Palimony is not recognized in Ohio." However, Ohio can recognize "implied" cohabitation contracts, resulting in palimony-type awards. • Oregon will look at couples' "oral statements and conduct over time" in order to determine palimony possibilities. • Pennsylvania has recognized palimony in the past, and has awarded palimony, as noted in the case of
Mullen v. Suchko (although this case occurred in 1980, when common-law marriage was still legal in PA, but common-law marriage was barred in PA in 2005) Although only a "tacit", or implied/oral, agreement is required in order for palimony to be awarded in PA, there is no online documentation online of any palimony cases after 1990. "Success often means proving the existence of an oral contract." -Quote from a Philadelphia lawyer. • Rhode Island supports a type of palimony called "unjust enrichment," where a paramour may lay claim to property that they do not own. • Texas law allows for some recognition of palimony. The Texas Family Code does not provide for "palimony.” This means you cannot gain rights under the Texas Family Code because you lived with someone absent a valid marriage. You can, however, create an agreement "on consideration of nonmarital conjugal cohabitation" under the Texas Business and Commerce Code (Tex. Bus. & Com. Code § 26.01(b)(3)). • Utah has no palimony laws. However, palimony lawyers do exist in Utah. • Vermont- No information in regard to Vermont palimony could be found online, except on blogs. Accordingly, "oral" contracts will be considered during palimony suits. • Virginia does have palimony lawyers. • "Washington courts reserve the power to equitable redistribute property from one unmarried partner to another acquired during a committed
intimate relationship." "Under Wisconsin law, cohabitants may bring a civil unjust enrichment claim upon termination of the relationship.
Watts v. Watts, 137 Wis. 2d 506, 405 N.W.2d 303 (1987);
Lawlis v. Thompson, 137 Wis. 2d 490, 405 N.W.2d 317 (1987)." However, "unlike maintenance, where the parties were married, in a cohabitation, performing household services does not give rise to claim for reimbursement. Rather, services must be linked to an accumulation of wealth or assets during the relationship.
Waage v. Borer, 188 Wis.2d 324, 525 N.W.2d 96 (Ct. App. 1994). There must be proof of specific contributions that directly led to an increase in assets or accumulation of wealth.
Ward v. Jahnke, 220 Wis. 2d 539, 583 N.W.2d.656 (Ct. App. 1998). (previous citation). "Wisconsin does not allow a palimony." (previous citation). a cohabitation lawsuit is a civil case, without standard forms and processes. As a result, if lawyers are needed in a cohabitation case, the cost may be significantly higher, as drafting pleadings is more expensive than simply completing forms. In addition, jury trials may be available, which could significantly increase the costs." (previous citation). • Wyoming recognizes certain types of palimony. ==Palimony-free states==