Facts
- A wealthy businessman and a woman of comparatively modest means married after a brief courtship; the marriage lasted about ten years.
- On the wedding day, the husband first presented a prenuptial agreement while the couple was selecting rings, with the ceremony imminent and honeymoon arrangements already made.
- The wife objected but signed after the husband stated that there would be no wedding unless she executed the agreement.
- The wife lacked a meaningful opportunity to consult independent counsel before signing.
- At marriage, the husband’s estate was about $3 million; by dissolution proceedings it had grown to about $25 million.
- The agreement provided that the husband’s premarital estate would remain his and that the wife’s alimony would be fixed at $1,000 per month in satisfaction of her support claim.
- In the dissolution action, the trial court enforced the agreement and awarded alimony consistent with its $1,000-per-month provision.
- The wife appealed, challenging the agreement’s enforceability and the trial court’s reliance on it.
Issues
- Whether the prenuptial agreement limiting the wife’s alimony and property rights was enforceable given its timing, the pressure to sign, and the parties’ unequal financial positions.
- Whether the trial court erred by treating the agreement as controlling in setting alimony and related economic relief.
Decision
- The appellate court reversed the portions of the dissolution judgment that enforced the prenuptial agreement.
- The court held the agreement invalid and unenforceable under the circumstances of execution and the resulting economic terms.
- The case was remanded for determination of alimony and related issues without giving controlling effect to the agreement.
Legal Principles
- Antenuptial agreements affecting support and property rights upon divorce are subject to heightened judicial scrutiny for both procedural fairness and substantive fairness.
- The spouse seeking enforcement must show the agreement was entered freely and voluntarily, with full and fair disclosure of financial circumstances or adequate knowledge reasonably attributable to the other spouse.
- Presenting an agreement on the wedding day and conditioning the marriage on immediate execution can negate voluntary consent where the other party lacks meaningful time for deliberation or independent legal advice.
- An agreement may be set aside when the support provision is unreasonably small or unconscionable in light of the wealthier spouse’s means and the circumstances at dissolution.
Conclusion
The court set aside a prenuptial agreement obtained on the wedding day through an ultimatum and without meaningful opportunity for informed consent, and required the trial court to reconsider alimony and related economic relief without enforcing the agreement’s limitations.