An award of spousal support will typically terminate on a specified date in the future, or
upon the death of either party, the remarriage of the spouse receiving spousal support,
or the cohabitation of the party receiving spousal support. While a date specific, death or
remarriage are pretty easy to determine, cohabitation is not.

Ohio Courts generally look to three (3) factors to determine cohabitation: (1) an actual
living together; (2) of a sustained duration; and (3) with shared day-to-day expenses.
Cohabitation is often described as an issue of lifestyle, not a housing arrangement.
Whether cohabitation exists is a question of fact to be determined by the court on a case-
by-case basis.

Frequently cohabitation is described as a relationship with an unrelated person of the
opposite sex in a relationship tantamount to marriage. In my experience as a domestic
relations attorney in the Cleveland/Akron area, cohabitation is extremely difficult to prove
and, most often, not worth the time and expense associated with trying to prove it.