Cohabitation—Will We Know It When We See It?
By Christopher Bohlen
Family Law,
January 2025
The issue is cases with similar fact patterns, but different results leave the parties involved with maintenance in a quandary. What is the meaning of residing in a continuing conjugal relationship? Recent cases have been able to define the concept. It is a de facto marriage. It is not an intimate dating relationship. But what is the bright line between those two concepts? Is it answered by Justice Stewart’s concept of “I know it when I see it”? More importantly, is the termination of maintenance based upon cohabitation so fact-specific and unpredictable as to argue for its elimination?
Musings of a Mediator: 15 Years Later
By Christopher Bohlen
Family Law,
January 2023
When Illinois Supreme Court Rule 905 was created, it gave a deadline to circuit courts to create rules for mandatory mediation of child issues in dissolution and parentage cases.
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