Alimony is a term commonly heard in family law cases in Georgia and around the country. As most people are aware, alimony refers to the temporary or permanent monetary support given to one spouse by the other spouse upon the dissolution of the marriage. O.C.G.A. §.19-6-1. But what happens to couples who have been together for many years, but never formally married? Do they have any standing to receive alimony-like support after a break-up? Surprisingly, in some states, they do, thanks to an "alimony without marriage" case from the 1970s. Michelle Triola Marvin, of Landmark Palimony Suit, Dies at 76, by Anahad O'Connor, The New York Times, October 30, 2009.
In that case, Michelle Triola Marvin, a little-known actress and singer, had a relationship with Academy Award winning actor, Lee Marvin. Though the two never married, they lived together and Triola Marvin adopted Marvin's last name. When they broke up, Triola Marvin took Marvin to court, "claiming that she deserved party of his $3.6 million fortune because their relationship had been based on an unwritten contract just as legitimate as a marriage certificate." At the hearing, Triola Marvin's lawyer argued that the parties had an oral agreement that Triola Marvin would give up her career to be Marvin's full time "companion, homemaker, housekeeper and cook", and, in return, Marvin agreed to provide all of her "financial support and needs for the rest of her life." While the Judge ultimately rejected Triola Marvin's claim that there was any sort of contract and, therefore, did not award her any portion of Marvin's fortune, he did award her $104,000 in rehabilitative alimony, which he called "palimony" (a combination of pal and alimony). The case established a precedent in allowing unmarried partners to sue for support. Though an appeals court eventually overturned her award, palimony still exists in some states.
In fact, a former girlfriend of Criss Angel is currently suing him for palimony, claiming they "essentially" lived together and had an agreement that he would support her. Criss Angel: My Ex Was a Girlfriend, NOT a Wife, by TMZ Staff, tmz.com, December 8, 2015. For his part, Angel claims that the parties were on and off for several years (never consistently together), and always kept financial things separate. It is unclear how this case will turn out, but it does show that the palimony issue is alive and well. It is important to note that the concept of palimony, or the award of monthly support payments to one partner upon the dissolution of a non-marital relationship, is not recognized in Georgia.