Intimate or romantic involvement
An intimate relationship does not necessarily require sexual intimacy. See Penrod, 29 Va. App. at 101, 510 S.E.2d at 246 (a couple's sexual relationship alone is not a sufficient consideration in determining cohabitation).
While sexual intimacy may provide significant proof of cohabitation, see Frey, 14 Va. App. at 275, 416 S.E.2d at 43, other indicia of a couple's close, interrelated functioning are equally important.
See Penrod, 29 Va. App. at 101, 510 S.E.2d at 246; see also Petachenko, 232 Va. at 299, 350 S.E.2d at 602. "'Cohabitation . . . imports the . . . continuing condition of living together and carrying out the mutual responsibilities of the . . . relationship.'" Schweider, 243 Va. at 248, 415 S.E.2d at 137 (quoting Petachenko, 232 Va. at 299, 350 S.E.2d at 602).
Compare Gordon v. Gordon, 342 Md. 294, 675 A.2d 540, 547 (Md. 1996) ("The ordinary definition of 'cohabitation,' describing a relationship of living together 'as man and wife,' connotes a mutual assumption of the duties and obligations associated with marriage").