California, United States of America
The following excerpt is from Gonzales v. Hudson, 200 Cal.App.3d 45, 245 Cal.Rptr. 753 (Cal. App. 1988):
The denial of a cause of action for loss of consortium for an unmarried cohabitant is also appropriate in view of the unworkability of the test articulated in Butcher v. Superior Court, supra, 139 Cal.App.3d 58, 188 Cal.Rptr. 503, which requires the courts to decide whether the cohabital relationship is "stable and significant." (Id. at
Page 757
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