Calo v. Calo
Where premarital cohabitation results in marriage, the “economic partnership” begins during the period of premarital cohabitation.
Where premarital cohabitation results in marriage, the “economic partnership” begins during the period of premarital cohabitation.
Cohabitation can be change in circumstances to stop maintenance.
Cohabitation may be change of circumstances warranting modification of maintenance.
Maintenance termination on cohabitation affirmed where boyfriend provided financial assistance.
Maintenance termination on cohabitation affirmed where boyfriend provided financial assistance.
Premarital contributions as unmarried cohabitator is not a relevant factor on wife’s maintenance claim.
Performing household services does not give rise to claim of unjust enrichment under Watts. Services must be linked to an accumulation of wealth or assets during the relationship.
Unjust enrichment award reversed where parties never held themselves out as husband and wife, maintained separate accounts and filed separate taxes.
Premarital relationship should have been excluded from consideration in maintenance decision. Review granted.
Court can consider premarital cohabitation as a factor in maintenance under ยง767.26(9) Wis. Stats.