What is a Committed Intimate Relationship in Washington state?
What a Committed Intimate Relationship Is
In Washington, a committed intimate relationship, or CIR, is a stable, marital-like relationship in which both people cohabit knowing they are not lawfully married to each other. Washington courts formerly called this a “meretricious relationship”; the terminology changed, but the doctrine concerns equitable property rights between unmarried partners, not whether they are legally married.[1]
“A ‘committed intimate relationship’ is a ‘stable, marital-like relationship where both parties cohabit with knowledge that a lawful marriage between them does not exist.’”[1]
Connell v. Francisco, 127 Wash. 2d 339, 346, 898 P.2d 831 (1995)
A CIR does not create a marriage or make the partners spouses. Rather, if a court finds a CIR existed, it may address property acquired during the relationship to prevent one partner from being unjustly enriched at the other’s expense.[2]
Factors Courts Consider
Washington courts consider five nonexclusive factors:
| Factor | What the court may examine |
|---|---|
| Continuous cohabitation | Whether the parties lived together in a stable, ongoing way. “Continuous” does not necessarily mean without any interruption; the nature and significance of time apart can matter. |
| Duration of the relationship | How long the relationship lasted. There is no fixed minimum duration, but duration is significant. |
| Purpose of the relationship | Whether the relationship involved a shared, committed life together, rather than simply dating or companionship. |
| Pooling of resources and services for joint projects | Whether the parties combined money, labor, or other resources for shared purposes or assets. |
| Intent of the parties | Whether their conduct and circumstances show a mutual intent to have a stable, marital-like relationship. The inquiry is not simply whether they intended to marry. |
The Washington Supreme Court described the factors as follows:
“continuous cohabitation, duration of the relationship, purpose of the relationship, pooling of resources and services for joint projects, and the intent of the parties.”[1]
In re Marriage of Pennington, 142 Wash. 2d 592, 601, 14 P.3d 764 (2000); Connell v. Francisco, 127 Wash. 2d 339, 346, 898 P.2d 831 (1995)
The factors are not a checklist: none is automatically controlling, and courts consider the total circumstances. The Washington Supreme Court has cautioned that a long relationship alone does not establish a CIR.[2]
Why the Finding Matters
If the court finds a CIR, it generally proceeds in three steps:
- Determine whether a CIR existed and when it began.
- Identify the parties’ interests in property acquired during the CIR.
- Make a just and equitable distribution of that property.
Property acquired during a CIR is generally presumed to belong to both partners, though that presumption may be rebutted. The presumption concerns property acquired during the relationship, not property acquired before it.[2]
In re Marriage of Pennington, 142 Wash. 2d 592, 602, 14 P.3d 764 (2000); Connell v. Francisco, 127 Wash. 2d 339, 349, 351, 898 P.2d 831 (1995)
Whether a CIR exists depends on the particular facts. In a specific case, the dates of cohabitation, time spent apart, shared financial or household arrangements, contributions to assets, and the parties’ statements and conduct may all be relevant.[1]