## Facts

- On the evening before their 1975 wedding, the husband’s attorney presented the wife with a prenuptial agreement.
- The wife, a 23-year-old unemployed nurse, signed the agreement without independent counsel and without legal advice from the husband’s attorney about rights surrendered.
- The husband was a 39-year-old neurosurgeon earning about $90,000 annually, with assets of about $300,000 at the time of marriage.
- The agreement limited the wife’s support upon separation or divorce to $200 per week, capped at a total of $25,000.
- The parties separated in 1982 and began divorce proceedings in 1984; the husband made payments satisfying the $25,000 cap.
- In 1985, the wife sought alimony pendente lite (APL); a master upheld the agreement and denied APL, the trial court dismissed exceptions, and the Superior Court affirmed.
- The wife challenged enforceability based on the timing of presentation, lack of counsel, alleged pressure, and asserted lack of understanding of APL and the agreement’s consequences.

## Issues

1. Whether prenuptial agreements should be enforced under ordinary contract principles absent fraud, misrepresentation, or duress, rather than subjected to judicial review for substantive “reasonableness” or a spouse’s subjective understanding of waived rights.
2. Whether the wife’s lack of independent counsel, late presentation, and claimed misunderstanding of APL invalidated her waiver of support beyond the agreement’s cap.

## Decision

- The Supreme Court of Pennsylvania affirmed enforcement of the prenuptial agreement and the denial of APL beyond its terms.
- The court held that, absent fraud, misrepresentation, or duress, spouses are bound by the terms of their agreements.
- The court rejected a special “reasonableness” review of prenuptial agreements and declined to require proof that the wife subjectively understood specific statutory rights, including APL, to make the waiver effective.
- Finding no fraud, misrepresentation, or duress in the record, the court enforced the $25,000 support limitation.

## Legal Principles

- Prenuptial agreements are governed by ordinary contract law and are generally enforceable as written absent fraud, misrepresentation, or duress.
- Courts do not invalidate prenuptial agreements merely because the bargain appears substantively unfavorable or because a party failed to read, fully understand, or obtain counsel before signing.
- A waiver of statutory support rights, including alimony pendente lite, is not ineffective solely due to a party’s lack of technical understanding of those rights, absent wrongful conduct such as fraudulent concealment or coercion.
- Judicial scrutiny focused on “reasonableness” and paternalistic protection is disfavored where the agreement is otherwise voluntary and free from legally cognizable misconduct.

## Conclusion

The court enforced the prenuptial agreement’s support cap and denied additional APL, holding that prenuptial agreements are evaluated under standard contract principles and are binding absent fraud, misrepresentation, or duress, without judicial reexamination of substantive fairness or subjective legal understanding.


Simeone v. Simeone, 525 Pa. 392, 581 A.2d 162 (Pa. 1990)