Matter of Bliss v. Bliss

In Matter of Bliss v. Bliss (66 NY2d 382 [1985]), the Court unanimously held that evidence that a former wife "habitually lived with another man" and that "the individuals may conform to the life style of a married couple is not enough" to warrant a modification in maintenance. (Id. at 387.) The Court held that "some objective evidence" of a "holding out" by the former wife that she is "the wife" of the other man is required. (Id at 387.) The Court gave, as an example, if the recipient's name is listed in a telephone directory or on a checking account using the (man's) surname.