McCluskey v. McCluskey
In McCluskey v. McCluskey, 528 So. 2d 328 (Ala. Civ. App. 1988), the Court of Civil Appeals found the evidence sufficient to support (though perhaps not to require) the trial court's finding of cohabitation: the former wife was not living full-time with her boyfriend, she and the boyfriend paid their own bills, and they maintained their own residences; however, the couple admitted that they stayed with each other 50%-75% of the time, that they had sexual intercourse, and that they considered their relationship open and notorious.