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that a payee was, in fact, cohabiting with another,
alimony would be modified to the extent that the one
cohabitant supports or subsidizes the other.46
Fast-forwarding to the current day, the reformers
regaled the legislators with stories of payees who were
‘gaming the system’—that is, obligees who are romantically, financially and socially intertwined with a new
partner, but avoiding marriage in order to continue
receiving alimony.47 Moreover, the legislators and
reformers alike could not understand why, when the
new relationship was proven, alimony should continue.
Notwithstanding a full explanation of the balancing of
policies cited by Justice O’Hern, they could not escape
the inherent unfairness.

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As a result, N.J.S.A. 2A:34-23n was inserted in
order to revise the law regarding cohabitation. The most
substantial change is that the economic needs test has
been eliminated; that is, once the cohabitation is proven
by the moving party, the court may only either suspend
or terminate (but not modify) alimony.
To determine whether there is cohabitation, there is a
list of six factors with a catch-all seventh factor. The focus
of these factors is on the quality and depth of the relationship: Do they share financial responsibilities? Do they
have joint assets and/or liabilities? Do they live together
and share household chores? Is there recognition of the
relationship in their family and social circles? In addition
to the factors, section n. notes that a court is to consider
the length of the relationship and that a court may not
find an absence of cohabitation solely on the grounds that
a couple does not live together on a full-time basis.48
In fact, the factors within section n. resemble the
characterizations of cohabitation recited by the Supreme
Court in Konzelman v. Konzelman:49

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A mere romantic, casual or social relationship is not sufficient to justify the enforcement
of a settlement agreement provision terminating
alimony. Such an agreement must be predicated on a relationship of cohabitation that can
be shown to have stability, permanency and
mutual interdependence. The Appellate Division
expressed that standard by defining cohabitation as a domestic relationship whereby two
unmarried adults live as husband and wife. 307
N.J.Super. at 159. Cohabitation is not defined or
measured solely or even essentially by “sex” or
even by gender, as implied by the dissent. Post
at 205. The ordinary understanding of cohabitation is based on those factors that make the
relationship close and enduring and requires
more than a common residence, although that
is an important factor. Cohabitation involves
an intimate relationship in which the couple
has undertaken duties and privileges that are
commonly associated with marriage. These can
include, but are not limited to, living together,
intertwined finances such as joint bank
accounts, sharing living expenses and household chores, and recognition of the relationship
in the couple’s social and family circle.50
In the author’s view, this change in the law can be
summarized as follows: The burden of demonstrating
cohabitation placed upon the payor is intentionally more
difficult to achieve; however, once the burden is met, the
consequence to the payee is more severe.
The final disagreement with the reform groups
concerned the ‘effective date’ of the statute. As previously
noted, the reformers sought retroactive application of the
statute; that is, like the Massachusetts law the reformers
wanted the new statute to apply to existing agreements
and judgments. The author believes there were numerous
arguments against retroactive application; as a sampling
of those arguments:
Article IV, Section VII, Paragraph 3 of the New Jersey
Constitution expressly prohibits the Legislature from
passing any law, “depriving a party of any remedy for
enforcing a contract which existed when the contract
was made.” N.J.Const. Art IV, §VII, Par. 3. In other words,
retroactive application of the law would be unconstitutional, as it would deprive payees of their rights under an
existing contract.
Quite often, a term and amount of alimony is one
part of a negotiated settlement. Take just one example—
a payor wants the tax benefit of designating a portion
of equitable distribution and, as such, the payor has
increased the term of alimony paid. Allowing retroactive
modification of the term of alimony, while ignoring the
context in which that level was determined and without
permitting the payee to concurrently modify the equitable distribution, is inequitable.
The courts are overburdened as it is; now imagine the
volume of alimony payors who would file applications to
review their obligations based upon the new statute.