In re Marriage of Saunders

Respondent filed a petition to terminate maintenance, arguing that petitioner was engaged in a resident continuing conjugal relationship with another person. The trial court found that petitioner was engaged in a de facto marriage and terminated the maintenance and petitioner appealed. The appellate court reversed, finding that the trial court’s finding of a de facto marriage as opposed to an intimate dating relationship was against the manifest weight of the evidence where the 17-month relationship did not demonstrate the permanence or commitment of a de facto marriage. (McDADE and ALBRECHT, concurring)