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In 1977, the Georgia legislature amended the law concerning the modification of alimony judgments and awards. In its amendment, the general assembly included what has come to be known as the "live-in lover" law. The "live-in lover" law gave courts the power to modify awards of alimony and support on petition of the husband. By statute, it was required that the husband show in his petition that the former wife was openly and continuously in voluntary cohabitation with another man.

The first challenge to the new law questioned its constitutionality. In Sims v. Sims, the Georgia Supreme Court, following the United States Supreme Court decision in Orr v. Orr, held that the "live-in lover" law was unconstitutional because it permitted modification only when the wife voluntarily cohabited with another man. To remedy the constitutional infirmity, the "live-in lover" law was amended in 1979 when the legislature attempted to bring all Georgia divorce and alimony law into compliance with the Orr decision. The new amendments made all Georgia domestic laws gender neutral. The Orr amendments also changed the "live-in lover" law by redefining cohabitation. After 1979, cohabitation was defined as "dwelling together continuously and openly in a meretricious relationship with a person of the opposite sex."

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