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n. a substitute for alimony in cases in which the couple were not married but lived together for a long period and then terminated their relationship. The key issue is whether there was an agreement that one partner would support the other in return for the second making a home and performing other domestic duties beyond sexual pleasures. Written palimony contracts are rare, but the courts have found "implied" contracts, when a woman has given up her career, has managed the household, or assisted in the man's business for a lengthy period of time. In the past 20 years palimony suits have proliferated, particularly against movie stars and wealthy businessmen, but the earliest was the famous California case of Sarah Althea Hill v. Senator William Sharon in the 1880s (she lost). The line between a mutual "affair" and a relationship warranting palimony is a difficult one which must be decided on a case by case basis. Palimony suits may be avoided by contracts written prior to or during the relationship.