## Facts

- Meagan Taylor Blige and Willie Alonzo Blige had one child (born 1994) and married in 2000.
- The day before the wedding, Willie took Meagan to meet an attorney Willie had hired for her.
- The attorney presented a fully drafted antenuptial agreement, reviewed it with Meagan, and she signed it; Willie signed later, and the wedding occurred as scheduled the next day.
- The agreement designated as Willie’s sole and separate property 19.5 acres in Bryan County, Georgia, including any house or structure situated on that property.
- At the time of marriage, no house existed on the land, but Willie had $150,000 in cash saved for building a home there.
- Meagan knew Willie worked as a delivery truck driver and generally knew his wages, but she did not know about the $150,000 and had no independent source of that information.
- After marriage, Willie used the $150,000 along with marital funds from both spouses to build the home; construction cost about $280,000, and the home was valued at roughly $375,000–$400,000 by trial.
- In 2005, Meagan filed for divorce; Willie counterclaimed to enforce the antenuptial agreement.
- After an evidentiary hearing, the trial court found Willie failed to make fair and clear disclosure of income, assets, and liabilities and set the agreement aside.
- A jury later awarded Willie the Bryan County property and home and awarded Meagan $160,000 as her equitable interest in the marital property, assigning each party debts in his or her own name.

## Issues

1. Whether the trial court abused its discretion by setting aside the antenuptial agreement for lack of fair and reasonable financial disclosure before execution.
2. Whether the jury’s $160,000 award to Meagan as an equitable interest in the marital home was erroneous or excessive.

## Decision

- The Supreme Court of Georgia affirmed.
- The court held the trial court did not abuse its discretion in setting aside the antenuptial agreement due to Willie’s material nondisclosure of the $150,000 cash asset.
- The court held the evidence supported the jury’s $160,000 award and found no error in the equitable division after the agreement was invalidated.

## Legal Principles

- Enforceability of an antenuptial agreement is evaluated under a three-part test: (1) whether it was obtained through fraud, duress, mistake, misrepresentation, or nondisclosure of material facts; (2) whether it is unconscionable; and (3) whether changed circumstances make enforcement unfair and unreasonable.
- Full and fair disclosure of all material financial facts is required; nondisclosure of a substantial asset may render the agreement unenforceable.
- Appellate review of a trial court’s determination on enforceability of an antenuptial agreement is for abuse of discretion, with deference to factual findings and credibility assessments.
- After a prenuptial agreement is set aside, a jury has broad authority to equitably divide marital property; an award will be upheld if supported by the evidence.

## Conclusion

The court upheld invalidation of the antenuptial agreement because Willie failed to disclose a material premarital cash asset used to build the home covered by the agreement, and it affirmed the jury’s $160,000 equitable award to Meagan as supported by the record.


Blige v. Blige, 283 Ga. 65, 656 S.E.2d 822 (Ga. 2008)