## Facts

- Lynn Gormley and Julia Robertson, an unmarried same-sex couple, cohabited from July 1988 to August 1998 in a long-term domestic partnership.
- At the relationship’s start, the parties’ incomes were similar; over time, Robertson (a physician) earned substantially more than Gormley (a nurse/administrator).
- The parties pooled resources through a joint bank account used to pay monthly obligations, including debts incurred before and during the relationship.
- In 1992, they borrowed $20,000 from Gormley’s father to consolidate debts, including a debt Robertson had incurred before the relationship; a balance remained at separation.
- In 1993, they purchased a Yakima, Washington home titled solely in Robertson’s name for financing convenience; mortgage payments and substantial improvements were funded from pooled resources.
- After separation, Gormley sued seeking equitable relief and an interest in property acquired during the relationship; Robertson disputed the legal framework and the division.

## Issues

1. Whether Washington’s meretricious-relationship doctrine applies to same-sex couples.
2. Whether the trial court properly characterized and equitably divided assets and liabilities acquired during the relationship, including the home and shared debts.

## Decision

- The Court of Appeals affirmed the judgment.
- The court held the meretricious-relationship doctrine applies to same-sex couples because the doctrine addresses marriage-like cohabitation where no lawful marriage exists.
- The court upheld the trial court’s equitable distribution of property and liabilities under that doctrine, including awarding Gormley a share of the home’s equity based on the parties’ joint contributions.
- A concurring judge agreed the result was correct, emphasizing general equitable principles rather than reliance on the doctrine’s label.

## Legal Principles

- Washington’s meretricious-relationship doctrine permits equitable distribution of property and liabilities acquired during a stable, marriage-like cohabiting relationship that is not a lawful marriage.
- The doctrine’s applicability turns on the relationship’s characteristics (including duration, continuous cohabitation, pooling of resources, and joint acquisition of property), not on the parties’ sexes.
- When a meretricious relationship is found, courts may allocate property interests based on the parties’ contributions and equitable considerations, notwithstanding record title.

## Conclusion

Washington law permits courts to treat long-term same-sex cohabitation as a meretricious relationship for purposes of equitably dividing property and debts accumulated through the parties’ joint efforts, and the trial court’s division in this case was affirmed.


Gormley v. Robertson, 83 P.3d 1042 (Wash. Ct. App. 2004)