Prenuptial agreements are contracts, and, as such, should be evaluated under the same criteria as are applicable to other types of contracts. Contracting parties are normally bound by their agreements, without regard to whether the terms thereof were read and fully understood and irrespective of whether the agreements embodied reasonable or good bargains.
At the time of their marriage in 1975, appellant Catherine E. Walsh Simeone was a twenty-three-year-old nurse and appellee Frederick A. Simeone was a thirty-nine-year-old neurosurgeon. Frederick had an income of approximately $90,000 per year, and Catherine was unemployed. Frederick also had assets worth approximately $300,000. Catherine filed a claim for alimony pendente lite. At trial, it was discovered that on the eve of the parties' wedding, Frederick's attorney presented Catherine with a prenuptial agreement to be signed. Catherine, without the benefit of counsel, signed the agreement. Frederick's attorney had not advised Catherine regarding any legal rights that the agreement surrendered. The parties were in disagreement as to whether Catherine knew in advance of that date that such an agreement would be presented for signature. Catherine denied having knowledge and claimed to have signed the agreement under adverse circumstances. She contended that this provided a basis for declaring it void. The lower court dismissed Catherine’s exceptions to a master's report that upheld the validity of a prenuptial agreement and denied her claim for alimony pendente lite from Frederick. The superior court affirmed the order of the lower court. Catherine sought review.
Was the prenuptial agreement valid and enforceable?
The Supreme Court of Pennsylvania affirmed, ruling the agreement was valid and enforceable and that Catherine could not receive alimony pendente lite. The court discarded an earlier approach that permitted evaluating the reasonableness of prenuptial agreements and held that such agreements should be interpreted using the same criteria as applied to other contracts. Absent fraud, misrepresentation, or duress, the spouses were bound to their agreement. It rejected Catherine's suggestion that the agreement should be voided because she had not consulted with an attorney and ruled that the reasonableness of the agreement was not a proper subject for judicial review. The Court also noted that ample evidence supported the findings of full disclosure of assets and the absence of duress.