The Rights of single people by Mitchell Bernard

By Mitchell Bernard

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STAT. ANN. D. CENT. C. CODE ANN. §161560 (included within the fornication statute); VA. 2345; W. VA. CODE §6184. 3. ALA. CODE §13A132. 4. , Wisconsin Act 17, §7 (1983). 5. , FLA. STAT. 02 (to 60 days; to $500); MASS. ANN. LAWS ch. 272, §16 (to 3 years; to $300); MICH. COMP. 335 (to 1 year; to $500); MISS. CODE ANN. §97291 (to 6 months; to $500); VA. 2345 ($500 fine). 6. Note, "Fornication, Cohabitation and the Constitution," 77 Mich. L. Rev. 8 (1978). 7. Id. 8. Briggs v. , 563 F. Supp. D. Mich.

2d 756 (1975)]; Butcher, supra note 3, the reasoning and holding were rejected by another California court of appeals in Hendrix v. , 193 Cal. Rptr. 922 (Cal. App. 1983). 11. In 1979, approximately 2,692,000 heterosexual couples lived in unmarried cohabitation arrangements. This figure is more than double the number in 1970. See, Comment, supra note 4, at n. 1 and the accompanying text. The incidence of cohabitation without marriage increased by 800 percent between 1960 and 1970. See Comment, "Consortium Rights of the Unmarried," 15 Family L.

San Jacinto Jr. College, 498 F. Supp. D. Tex. 1980) (adulterous relationship is not protected by the Constitution); Wilson v. Swing, 463 F. Supp. C. 1978); Hollenbaugh v. Carnegie Free Library, 436 F. Supp. D. Pa. 1977), cert. S. 1052 (1978). But other courts have joined with Briggs, supra note 8, in holding that the Constitution does protect such conduct. , Baker v. Wade, 553 F. Supp. D. Tex. 1982); Shuman v. City of Philadelphia, 470 F. Supp. D. Pa. 1979); Smith v. Price, 446 F. Supp. D. Ga. 2d 1371 (5th Cir.

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