‘Big win for clarity’: New Jersey Supreme Court sets benchmark for cancellation of child support payments

In a ruling lauded by family lawyers across the state, the New Jersey Supreme Court ruled that a party wishing to end alimony need not meet all of the Konzelman cohabitation criteria in order to have prima facie cohabitation v. Konzelman or the State Support Act.

In the underlying case, Suzanne and Michael Cardali entered into a property settlement agreement in 2006, which provided that he would pay her child support until she “lived together,” as defined by New Jersey law, the statement said. In December 2020, Michael Cardali filed a request to end alimony, stating that he believed Suzanne Cardali had been in a relationship equivalent to marriage for eight years. He also produced a private investigator’s report showing that Suzanne Cardali and the man she is romantically involved with were together on all 44 days of the surveillance and that, among other things, they were together overnight more than half of those days.

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