Appellate Court Reverses Financial Awards Where Trial Court Disregarded Terms of a Valid and Enforceable Antenuptial Agreement, Supreme Court Affirms
by
Joseph C. Maya on Mar. 25, 2024
Summary: In a divorce action, the Appellate Court of Connecticut reversed, in part, a trial court’s awards of alimony, child support, and lump sum property settlement without regard to the terms of a validly executed antenuptial agreement. Upon further review, the Supreme Court of Connecticut upheld the judgment of the Appellate Court.
The Case
In this case, the plaintiff wife and defendant husband worked for the same employer, after which they became engaged. This was the husband’s second marriage, and he believed that he was “burned” in his previous divorce. Therefore, approximately one year before the wedding, the husband talked to his wife about his desire to draft and execute an antenuptial agreement as a precondition of marriage. Per its terms, the parties would each retain their own present and future property free from any and all claims by the other party (even as widow or widower). The wife consulted her attorney, who advised her not to sign the agreement, but the wife did so voluntarily because she “made a commitment.”
After approximately sixteen years of marriage, the wife filed for divorce, at which point the husband sought to enforce the antenuptial agreement. The trial court found it unenforceable because the economic circumstances of the parties had “changed significantly” from the time the agreement was signed to the dissolution action. The court instead made awards of child support, time limited alimony, and a lump sum property settlement to the wife, along with other orders, and the husband appealed.
Antenuptial Agreements
Antenuptial, or prenuptial, agreements are construed under contract principles. As such, courts must consider party intent when construing the language of the agreement. Antenuptial agreements that involve property (and rights of the parties with respect to that property) are generally enforceable if a three-part inquiry is satisfied affirmatively:
(1) [T]he contract was validly entered into; (2) its terms do not violate statute or public policy; and (3) the circumstances of the parties at the time the marriage is dissolved are not so beyond the contemplation of the parties at the time the contract was entered into as to cause its enforcement to work injustice.
McHugh v. McHugh, 181 Conn. 482, 485-486. Applying this standard to the facts in this case, the Appellate Court determined that the trial court’s finding regarding a change in circumstances was not factually supported. The assets of both parties increased during the course of the marriage simply due to maintained employment. The wife did not provide any facts indicating that the nature of the husband’s employment changed over the course of their marriage.
The Court’s Decision
The Appellate Court stated that the financial circumstances of the parties at the time of dissolution did not differ from what they contemplated when they signed the agreement. It noted that its terms made reference to both future employment and the possibility of having children. In addition, the wife understood her husband’s wish to protect his property by segregating it, which serves as evidence that the parties knew that a divorce could occur down the road – as such, they prepared for this possible eventuality. Therefore, the Appellate Court found that the three requirements of McHugh were satisfied, and reversed with respect to this aspect of the appeal.
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