In a modification of alimony proceeding involving a supportive relationship, alimony can be reduced where a cohabitant provides support to a payee or the payee contributes to the support of a cohabitant. In Murphy v. Murphy, the Florida Court of Appeal recently stated: “To find a sufficient change in circumstances to warrant a reduction or the termination of alimony based on cohabitation, a trial court is required to consider whether either of the following two factors is present:
‘ whether the cohabitant provides support to the recipient spouse, or  whether the recipient spouse contributes to the support of the cohabitant.’ Bridges, 842 So. 2d at 984 (citing Maclaren v. Maclaren, 616 So. 2d 104, 106 (Fla. 1st DCA 1993)) (emphasis added). For example, in Stuart v. Stuart, 385 So. 2d 134,135 (Fla. 4th DCA 1980), the Fourth District recognized that cohabitation relationships necessarily will result in either financial or in kind contributions flowing from the former spouse to the new partner or vice-versa, explaining: Obviously, if a spouse receiving alimony enters into an arrangement which involves living with a member of the opposite sex, that is rather clear evidence of a substantial change of circumstances. There will either be financial or in kind contributions of the new partner to be taken into account, or, if the contributions go from the spouse to the new partner, the fact that the spouse is providing board and room to the new partner is evidence that the fair market value of those and any other contributions is some measure of the extent to which periodic alimony is excessive. (emphasis added)…The statute specifically provides that a supportive relationship may exist if, in whole or in part, either the obligee or the other person is supporting the other, is providing valuable services for the other, or providing support to the other’s children. See § 61.14(1)(b)2.d., e., k. The impact that a third party cohabitant’s contributions, financial or otherwise, may have on the former spouse’s need is merely a relevant consideration as to whether to reduce or terminate alimony after a determination is made that a supportive relationship exists. King, 82 So. 3d at 1129…”
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