Co-Habitation Agreements, also known as Marvin or Anti-Marvin Agreements

These agreements are often created to set the parties’ expectations in the wake of the Marvin case and its progeny. In 1971, actor Lee Marvin was sued by Michelle Triola, his live-in girlfriend of 7 years, who sought compensation after the end of their relationship even though the parties were never married. Michelle alleged that she and Lee “entered into an oral agreement” that while “the parties lived together they would combine their efforts and earnings and would share equally any and all property accumulated as a result of their efforts whether individual or combined.” She also claimed that she agreed to “give up her lucrative career as an entertainer [and] singer” in order to “devote her full time to [Lee] . . . as a companion, homemaker, housekeeper and cook;” in return [Lee] agreed to “provide for all of [Michelle]’s financial support and needs for the rest of her life.” The California Supreme Court held that in these kinds of cases, even though the Family Code does not apply, one party can receive money from the other if he or she can prove the existence or an express or implied contract.

The parties at the end of a live-in nonmarital relationship often have sharply conflicting positions. One party may think “She lived in my house rent-free for years, paid no bills, and after I took care of her she wants WHAT?”, while the other party may think “I cared for him for years, moved in with him, helped raise his kids from a prior relationship (or our kids), gave up my career to be a housekeeper, and now I am being left with nothing.” To avoid having these disputes litigated at great expense, people often enter into agreements which list their rights and expectations regarding their live-in relationships. Things you cannot contract for include “meretricious sexual services” and other provisions which violate public policy.

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