## Facts

- Randall J. Shanks, an Iowa attorney with a successful practice, and Teresa E. Shanks, who had post-secondary education and worked in Randall’s office, married on April 23, 1998; it was a second marriage for both and each had children from prior marriages.
- About ten days before the wedding, Randall presented Teresa with a premarital agreement he drafted and told her to obtain independent legal advice.
- Teresa consulted a Nebraska attorney who advised seeking Iowa counsel; Teresa declined additional counsel and signed a revised agreement six days before the wedding.
- The agreement generally treated premarital and marital acquisitions as separate property, limited jointly owned property largely to a marital home and joint checking account, waived alimony, and divided only jointly owned property upon divorce.
- The agreement included schedules listing each party’s assets with approximate values and required Randall to maintain $500,000 in life insurance naming Teresa as beneficiary.
- The marriage deteriorated in 2004, and dissolution proceedings followed; Randall sought enforcement of the premarital agreement and Teresa resisted, claiming involuntariness, unconscionability, and inadequate disclosure under Iowa Code § 596.8.

## Issues

1. Whether Teresa proved the premarital agreement was not executed voluntarily under Iowa Code § 596.8(1).
2. Whether the agreement was unconscionable at the time of execution under Iowa Code § 596.8(2).
3. Whether enforcement was barred for lack of fair and reasonable disclosure and lack of knowledge of Randall’s financial condition under Iowa Code § 596.8(3).

## Decision

- The Iowa Supreme Court held the premarital agreement was voluntarily executed, not unconscionable, and enforceable under Iowa Code § 596.8.
- The court vacated the court of appeals decision.
- The court affirmed in part and reversed in part the district court’s judgment and remanded for further proceedings consistent with its opinion.

## Legal Principles

- Under Iowa’s Uniform Premarital Agreement Act, the party seeking to avoid enforcement bears the burden to prove statutory grounds for invalidity, including lack of voluntariness.
- Conditioning marriage on execution of a premarital agreement, without unlawful threats, fraud, or overreaching, does not by itself establish duress or involuntariness.
- Unconscionability at execution includes both procedural concerns (process, understanding, bargaining conditions) and substantive concerns (whether terms are harsh, oppressive, or one-sided).
- “Fair and reasonable disclosure” under Iowa Code § 596.8(3) does not require a formal accounting; reasonably detailed schedules plus the challenger’s practical knowledge of the other party’s finances can satisfy the disclosure and knowledge requirements.

## Conclusion

The Iowa Supreme Court enforced the parties’ premarital agreement, ruling that Teresa did not prove involuntariness, the terms were not unconscionable when signed, and the disclosure and Teresa’s knowledge of Randall’s finances met Iowa Code § 596.8.


In re Marriage of Shanks, 758 N.W.2d 506 (Iowa 2008)