In the case of Stroud v. Stroud, the Virginia Court of Appeals ruled that a husband could terminate spousal support payment to his ex-wife where ex-wife began living with her lesbian partner. Significantly, wife sent out a Christmas letter which alerted husband to the living arrangment. The letter was introduced into evidence. The matter was controlled by the language of the husband and ex-wife's separation agreement which stated that husband's support payments would terminate upon wife's "cohabitation with any person ... in a situation analogous to marriage."
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