Boland v. Catalano
In Boland v. Catalano, 202 Conn. 333, 521 A.2d 142 (1987), the Court adopted the holding of the California Supreme Court in Marvin v. Marvin, 18 Cal.3d 660 (1976), that "the courts should enforce express contracts between nonmarital partners except to the extent that the contract is explicitly founded on the consideration of meretricious sexual services. . . . In the absence of an express contract, the courts should inquire into the conduct of the parties to determine whether that conduct demonstrates an implied contract, agreement of partnership or joint venture, or some other tacit understanding between the parties." Boland v. Catalano, supra, 202 Conn. at 340-41.
The Boland court also expressly ruled, in adopting Marvin v. Marvin, that the court may also employ "equitable remedies" when warranted by the facts of the case. Id. at 341.
If before or during purportedly entering the Vermont civil union, the parties to this action entered an implied or express contract to "share their earnings and the fruits of their joint labor," the court had jurisdiction to grant relief in law or equity as to that claim. Id. at 342. "Ordinary contract principles are not suspended . . . for unmarried persons living together, whether or not they engage in sexual activity." Id. at 339.