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Citing a recent New York Times article, Victor Medina in the New Jersey Divorce and Family Law Blog, comments on the rise in the use of post-nuptial agreements, a trend I noted several months ago, here.

Mr. Medina gives a great description of what post- nuptial agreements really are:

What are “post-nuptial agreements”? Well, unlike pre-nuptial agreements, which deal with parties interested in getting married before they’re actually married, and unlike property settlement agreements, which deal with parties interested in not being married after they’re actually married…post nuptial agreements are intended for a married couple who did not previously enter into a premarital agreement and, despite wanting to be married, would like to plan for the division of property in case they later get divorced.

Against this back drop, he provides the minimum requirements for a post-nuptial agreement to be upheld in New Jersey.

1) There needs to be full disclosure by the parties.
2) Each party must have independent representation by his/her own lawyer.
3) There needs to exist the absence of coercion or duress.
4) The terms must be fair and equitable.

In New York, the requirements are quite similar, the agreement must be properly signed and acknowledged and entered into without fraud, coercion or duress. The agreement cannot be unconscionable.

One way of assuring that a martial agreement will be upheld, is to have full disclosure of assets, liabilities and income. In addition, the parties should each be independently represented by counsel.

While all agreements are subject to attack and there is no certainty that any agreement will be upheld, New York courts encourage parties in a matrimonial setting, to put their affairs in order by written agreement. The terms of a valid martial agreement will be enforced and there is a heavy burden on the party attacking the agreement to show why it should be set aside.

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Yesterday, I noted that there seemed to be a rash of cases challenging the validity of prenuptial agreements. Today, I continue my review with a case the sends the message that you had better read and fully understand the agreement before you sign it, particularly if you are “well educated.” Blindly entering into an agreement will not invalidate it.

In Stawski v Stawski, the Appellate Division upheld the validity of a prenuptial agreement, written in German and signed by an American citizen, in Germany. At the time of its execution, the wife-to-be did not speak German and was not represented by an attorney. Instead, the “notar,” before whom the agreement was signed, simply read and explained the agreement to the parties.

The Court found it significant that the well educated wife voluntarily signed the agreement and did not ask any questions about it prior to its execution.

The agreement provided that each party would retain ownership of their separate property held at the time of the marriage or acquired thereafter. During the length of the marriage, the Court found that:

[D]espite her asserted lack of understanding, she acted in accordance with the terms of the agreement throughout the marriage, maintaining separate bank accounts in her own name in which she deposited income from properties she inherited from her family, which properties were themselves also retained by plaintiff solely in her name.

The Appellate Division restated the public policy that:

[T]his State favors " individuals ordering and deciding their own interests through contractual arrangements'" (Van Kipnis v Van Kipnis, __ AD3d __, 2007 NY Slip Op 06074, *5 [July 12, 2007], quoting Bloomfield v Bloomfield, 97 NY2d 188, 193 [2001]), and thus, duly executed prenuptial agreements, including agreements executed in a foreign country, are accorded the same presumption of legality as any other contract.

Notwithstanding the fact that wife did not read the agreement written in German and had no legal representation at the time it was signed, the Court declined to set aside the prenuptial agreement, stating

”I]f defendant "did not read or understand the agreement, or have any explanation of the same, his conduct evidenced a degree of carelessness or negligence not to be expected of a sophisticated and mentally brilliant person" (id.). One need not be an attorney or a Fulbright scholar to know the folly of signing a legal document without an understanding of its import.

In short, a Court is not going to excuse you from an agreement you voluntarily sign if you fail to read it. The fact that agreement is written in a language you do not understand is of no import. I wonder if the result have been different if the wife was not well educated?

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Thank you to the Prenuptial Agreement Blog for including me in the list of Top Family Law Blogs.

Speaking of prenuptial agreements, a couple of cases addressing prenuptial agreements have been decided by the Appellate Division in recent weeks. Thus, I begin a series of postings addressing these cases.

In the recent case of Selinger v. Selinger, the parties entered into a prenuptial agreement, in which they agreed “to waive any rights in and to the other's separate property, including gifts of land to the other as long as the gift was either evidenced in writing or "such records or the title of the donated property must have been changed into the name of the donee party."

During the course of the marriage, the parties sold a home that husband solely owned prior to the marriage, and purchased a house in Long Island with legal title to that house being placed solely in wife's name. When the home was sold, the sale proceeds, $3.4 million dollars were deposited in the wife’s separate bank account.

The Court ruled that the proceeds were the wife’s separate property.  “By deeding the house to defendant, plaintiff memorialized in writing a gift to his wife pursuant to the clear terms of the prenuptial agreement. . .”

The opinion hints that there was another, but unenforceable agreement executed between the parties, which I bet, obligated the wife to transfer the property or its proceeds back to the husband in the event of divorce.

There certainly was something improper going on that was not directly addressed in the opinion. I am guessing that the transfer to the wife was an attempt to protect the property from the creditors of the husband.

In any event, this case serves as a lesson that a prenuptial agreement will be upheld, even if it results in a wind-fall for one of the parties.

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The New York Probate Litigation Blog highlights the recently decided case of Estate of Joseph Menaham, in which a widow’s attempt to nullify a pre-nuptial agreement was rejected by the Surrogates’ Court.

Prior to marriage, the wife, now a widow, was diagnosed, hospitalized and treated for a bipolar disorder. Following her release, she entered into a pre-nuptial agreement in which the parties each agreed waived their rights to election against the other’s estate. The right of election is a statutory protection which prevents one spouse from dis-inheriting the other.

Following her husband’s death, the widow sought to set aside the pre-nuptial agreement claiming that the bipolar disorder left her unable to knowingly execute the prenuptial agreement.

Surrogate Lopez-Torres noted that a "duly executed prenuptial agreement is given the same presumption of legality as any other contract, commercial or otherwise. It is presumed to be valid in the absence of fraud." The court further referred to section 5-1.1-A(e)(2) of the Estates Powers and Trusts Law which sets forth the requirements for an effective waiver of a spouse's right of election against the estate of a deceased spouse. Such a waiver or release must be in writing, signed, acknowledged and in "recordable" form which means that such a waiver must follow the same form as would be used to provide for the recording of a deed to real property.

The Court viewed this claim with the proper amount of cynicism and found that the widow failed to prove that she lacked the competence to enter into the agreement. As noted in the New York Probate Litigation Blog, the widow earned a professional degree during the marriage and never challenged the validity of the agreement until her husband’s death.

The real focus of the inquiry must be was the wife competent at the time she entered into the agreement. While her mental capacity before and after she signed the agreement may be of some probative value, it should not be dispositive of the issue. If a person could avoid the intended, but harsh consequence of an agreement merely by alleging that at some prior time, he suffered from metal illness, every agreement would be at risk to a subsequent challenge.

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Postings in two divorce and family law blogs highlight a growing conflict between the states on how to deal with a parties continuing obligation to pay alimony or maintenance, as it called in New York, if the former spouse enters into a domestic partnership.

To frame the issue, what happens if you are obligated to pay maintenance to your ex, but your ex rather than  re-marrying, enters into a domestic partnership? A number of states have enacted civil union or domestic partnership statutes which grant same sex couples some, but not all, of the rights and privileges of marriage. Maintenance or alimony typically terminates when the receiving spouse remarries.

The New Jersey Law Blog provides an excellent survey of the issue, contrasting a case from Virginia, which held as a result of the domestic partnership alimony should terminate, and one from Oregon, which held that the support obligation should continue.

The Florida Divorce Blog reports on a California decision in which the court ruled that a domestic partnership “is mere cohabitation and not a marriage.” Therefore, the alimony payments were ordered to continue.

To avoid uncertainty and litigation, this issue must be addressed in a settlement agreement at the time of divorce. If it is the parties’ intention that maintenance should terminate in the event of a cohabitation (same sex or opposite sex), the entry into marriage or a domestic partnership or civil union, the settlement agreement should make special provision. The failure to address t his issue exposes the parties to an unknown and presently unpredictable future determination.

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The Appellate Division in Walker v. Walker provides us with yet another lesson on the importance of carefully drafting martial agreements.

In Walker, the parties, in an oral stipulation of settlement, agreed to divide a 75 acre property. The stipulation specifically provided that defendant "would be entitled to one-half or 37½; acres off the westerly side of that parcel of 75 acres (emphasis added)."  Not surprisingly, the parties then had a dispute about how the property was to be actually divided.

On appeal, the Court found that the stipulation was ambiguous,

because there is no mechanism by which to determine how much of defendant's 37½; acres must be from the "westerly side" of the parcel. Stated otherwise, the stipulation provides no basis from which to discern a dividing line.

As the result of a simple, and, perhaps, misplaced “or” in a settlement agreement, the parties were forced to perfect an appeal and to conduct a hearing to clear up the ambiguity and to ascertain their intent at the time (they thought) they settled the case.

The lesson, select the language of agreements carefully. If necessary, give examples. In this case, an illustration on the land survey showing how the property was to be divided would have saved this couple a lot of legal fees and heartache.

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James Andrew Miller wrote a compelling op-ed piece in the New York Times, theorizing that expensive and heart wrenching custody battles could be avoided if parties intending to marry, merely entered into a pre marital agreement. He details the understandable outrage of friends, told by their soon to be ex-spouses that they would be allowed to have visitation with their children.

However, what Mr. Miller ignores is that parties can contract to virtually any issue of the marriage except child custody and support. Any provisions would be contrary to public policy and would be unenforceable.

 Child custody is based upon the best interests of the children.   It would be virtually impossible to make a best interests determination when the parties are first getting married and before children are even born. For this reason, a custody determination should only be made at the time parents elect to divorce.  

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The Appellate Division in Van Kipnis v. Van Kipnis enforced a pre-nuptial agreement which the parties entered into in France in 1965.  The agreement provided that “Each spouse shall retain ownership and possession of the chattels and real property that he/she may own at this time or may come to own subsequently by any means whatsoever.”

Although there is a presumption under New York law that property acquired during the marriage is marital, the Court found that the presumption was overcome by the unambiguous terms of the parties’ agreement and their conduct in keeping their assets separate. As a consequence, the parties’ separate assets were not subject to equitable distribution.

In rendering this decision, the Court offered a primer on the relevant law  of matrimonial agreements. Among the basic concepts elaborated upon are:

• There is a "strong public policy favoring individuals ordering and deciding their own interests through contractual arrangements" (Bloomfield v Bloomfield, 97 NY2d 188, 193 [2001] Thus, "[d]uly executed prenuptial agreements are accorded the same presumption of legality as any other contract.”
• "Agreements are to be construed in accord with the parties' intent."
  
• The best evidence of what parties to a written agreement intend is what they say in their writing."
• A written agreement that is complete, clear and unambiguous on its face must be enforced according to the plain meaning of its terms.
• Extrinsic evidence of what the parties really intended is generally inadmissible, and will be considered only if the agreement is found to be ambiguous, W.W.W. Assoc., v Giancontieri 77 NY2d 162 [1990]).
• Extrinsic evidence may not be utilized to create an ambiguity that would otherwise not exist

The decision can be read here.

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Governor Spitzer signed into law, this week, a bill amending Domestic Relations Law  §250, tolling the three year statute of limitations for commencing an action or asserting a defense that arises from a pre-nuptial or post nuptial agreement until service of process has been completed in a divorce action or until one of the parties dies. The law does not apply to separation agreements or agreements entered into during the matrimonial action.

What this means in plain English is that a party does not have to take any action to enforce or to declare void a marital agreement until an action for divorce or annulment is commenced.

This amendment makes sense. It would be impractical to require a party, during an intact marriage, to contest or change the terms of prenuptial agreement. Under the amended law, any dispute over the marital agreement would need to be asserted within three years of the commencement of a matrimonial action.

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A father, who had agreed to contribute to his child’s college education, was not responsible for contributing to the costs of the child’s post-graduate degree. In the recently decided case of Robinson v. Gerny (New York Law Journal) (subscription required), the Court ruled that “The word ‘college’ denotes attendance at an undergraduate program resulting in a bachelor’s degree.”

The Court ruled that the fact that the child was seeking a graduate degree was not “contemplated as within the plain meaning of college.”

This dispute could have easily been prevented by carefully drafting the parties’ settlement agreement. It is not uncommon to provide in a settlement agreement that child support will be paid for so long as a child is registered and attending an undergraduate degree on a full time basis. Indeed, Justice Pines decided this case by applying basic tenets of contract construction, giving words and phrases their plain and ordinary meaning.

If there is a lesson to be learned from this case, it is that the scope and duration of a party’s obligation to contribute to a child’s higher education should be clearly defined in clear and unambiguous language

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The Oklahoma Family Law Blog highlights some of the basic tax concerns that need be considered in connection with divorce.  

• Alimony is taxable and deductible. The person who provides alimony can claim the payments as a deduction, while the person who receives it can avoid a large end-of-year tax bill by paying estimated taxes during the year. Unlike alimony, child support is not deductible or taxable.
• Who claims the children? The parent who has custody of a child usually can claim the child as a dependent. However, with the custodial parent’s consent, the parent without custody can claim the child. (The custodial parent may still be able to claim certain tax benefits related to the child, including head of household filing status, the Earned Income Tax Credit, and the child-care credit.)
• Who is a head of household? There are several factors for determining the head of a household. A few include being considered “unmarried” on the last day of the year, having children or other dependents who live with you, and paying more than half the cost of providing a home for dependents. Taxpayers should consult with a tax professional to determine if they qualify for head of household status.
• Divorce, annulment and legal separation are considered the same by the IRS for tax purposes. The way a tax return is affected by the situation depends on how the decree is worded, and in cases where state and federal law differ, the IRS will side with the federal government.

Taxes may even be used to facilitate settlements. For instance, by using the differential in tax rates between spouses, a settlement can be structured so that, in essence, taxes subsidize some maintenance payment.

For this reason I suggest that a settlement proposal be examined by a tax professional or a certified divorce financial planner.

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The Wall Street Journal in an article entitled Divorce: Counting Money Gets Tougher, highlights the common mistakes made by unwary litigants. These mistakes can have dire tax consequences.

Some common blunders: Dividing a stock portfolio down the middle without checking for losses or gains -- which can trigger either a tax break or a big capital-gains tax hit.

There are steps you can take to avoid house-related tax hits. If you keep the house and retitle it in your name, but end up selling it after the split, you may be able to shield only as much as $250,000 of the gains from capital-gains taxes. Consider selling the house while you're still married, or include specific provisions for the sale of the house in the divorce decree, to shield as much as $500,000 from capital-gains taxes.

The QDRO -- short for Qualified Domestic Relations Order -- is a court order that spells out who gets what in an employer-sponsored retirement plan such as a pension or a 401(k). QDROs must be approved by both the employer's retirement-plan administrator and the divorce-court judge.

The document lets you make transfers to an Individual Retirement Account, or make early fund withdrawals from the plan without paying the usual 10% IRS penalty if you're under age 59½. (You'll still have to pay income taxes on withdrawals.)

Try to complete the QDRO before the divorce is finalized. Otherwise, if your ex should die, remarry or leave the company, it may be tough to receive any retirement money.

Adding to the confusion, IRAs don't require QDROs. If you write it in your divorce agreement, you can split an IRA by transferring the funds directly into other IRAs without being subject to penalties or taxes.

If you're paying alimony, you can claim the payments as a deduction. But if you receive alimony payments, they count as taxable income. Child-support payments are neither deductible nor taxable.

Other tips: Take out a term life-insurance policy on the alimony-paying spouse. And update wills, trusts and beneficiary designations on retirement plans and insurance policies, so that your ex doesn't end up inheriting an unintended windfall.

An easy way to avoid making bad financial decisions incident to the divorce is to consult with a certified divorce financial planner. I have found, in some cases, a certified divorce financial planners assistance to be invaluable.

After analyzing the client’s finances, cash flow, work and income history, this professional can run “what-if" and tax impacted scenarios on settlement proposals. In this way, a settlement can be specifically structured to the client’s present and future after tax financial needs.

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The Financial Times reports that there is a growing trend for post nuptial agreements.   Like the pre-nuptial agreement, the post-nuptial agreement sets out the parties’ rights, obligations and liabilities upon the termination of marriage by either death or divorce. The only difference between the two marital agreements is that the post-nuptial agreement is executed sometime after the parties are wed.

According to the Financial Times, post-nups are particularly popular with hedge fund managers.   This, however, makes perfect sense.   The financial tycoons are merely seeking to limit their downside risk in the event that their marriages become, to use the street slang, “bearish” (or in the event they want to seek other opportunities.)

The article notes that at least one hedge fund requires its new partners to have a marital agreement in which the partner’s spouse waives his/her claims against the fund.   The hedge fund firms are looking to protect themselves since the partnership interest is a marital asset and is subject to equitable distribution.   In order to ascertain the value of the partnership interest, the partnership needs to be appraised opening the door to an inspection of the hedge funds books and records.

So why would a spouse waive his or her claim against partnership interest in the hedge fund? The spouse is probably banking that the marriage will continue and he/she will continue to enjoy the lifestyle afforded by interest in the hedge fund. But, in the event the marriage ends in divorce, the consideration for the waiver is probably a generous distributive award.   

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It seems to be just common that when negotiating any type of marital agreement, it is important to make sure that your every intention is clearly spelled out, even if the intent seems obvious to you..  Such is the lesson of recently decided case of Genovese v Axel.

In Genovese:

[T]he parties executed a prenuptial agreement dated April 17, 2000, whereby they agreed to waive their respective rights of election pursuant to EPTL 5-1.1-A. Following the waiver provision, the parties agreed, in clause 1(ii), that "[n]otwithstanding anything to the contrary" they would each "execute their respective Last Will & Testament[s] leaving a minimum of 33 1/3% of their gross estate to each other."

Needless to say, a few years later the parties divorced. Following the divorce, the ex-wife sought to have her husband name her as a one third beneficiary of his estate.

It seems obvious that it was the the couple’s original intent  to make reciprocal obligation to name the other as a beneficiary of his/her estate conditioned upon the continuation of the marriage.  Nothing in the opinion indicates that the parties wished to bind  their post divorce estates.  Unfortunately, , the parties had to spend thousands in legal fees and go as far as the Appellate Division to reach this result.

Where an agreement is clear and unambiguous on its face, as here, the intent of the parties is gleaned from the four corners of the writing as a whole with a practical interpretation of the language employed so that the parties' reasonable expectations are met (see W.W.W. Assoc. v Giancontieri, 77 NY2d 157, 162; Rainbow v Swisher, 72 NY2d 106, 109; Sunrise Mall Assoc. v Import Alley of Sunrise Mall, 211 AD2d 711). In examining the agreement, the court should consider the relation of the parties and circumstances under which it was executed. "Particular words should be considered, not as if isolated from the context, but in the light of the obligation as a whole and the intention of the parties as manifested thereby" (Kass v Kass, 91 NY2d 554, 566 quoting Atwater & Co. v Panama R.R. Co., 246 NY 519, 524).

The one-third provision appears under the heading "release of rights," in which the parties employed language such as "surviving spouse" and "deceased spouse," which evidences their intent that the parties remain married in order to receive a one-third disposition under each other's will. The plaintiff contends that the use of the phrase "notwithstanding anything to the contrary" demonstrates that the parties intended the one-third provision to remain in effect regardless of their marital status. We disagree. That language modifies the previous provision, in which the parties waived the spousal right of election. The plaintiff's interpretation would require this court, under the guise of interpretation, to imply a provision that the parties chose to omit (see Karmin v Karmin, 19 AD3d 458, 459), namely that the obligation contained in clause 1(ii) would extend to one who was no longer a spouse.

The morale of the story, when drafting an agreement, make sure that the agreement is as clear as possible.  Do not trust anything to extrinsic or common sense interpretation . If there is a dispute over the agreement, rest assured, the person with whom you have a dispute will have a different recollection of the basis of the bargain.  

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Continuing along the theme of sport superstars and their very public divorces, Jeffrey Lalloway in his blog, reports that:

Giants star Michael Strahan was ordered to pay his ex-wife $15.3 million -- more than half his net worth -- in keeping with the couple's prenuptial agreement.

Under the agreement, Jean Strahan was entitled to 50 percent of their joint marital assets and 20 percent of his yearly income from each year they were married.

The NFL star had contended he wasn't responsible for the 20 percent because his wife failed to ask for it every year. But state Superior Court Judge James Convery disagreed, ruling "the plaintiff is not credible in his claim that the defendant never asked for her separate funds." In addition to the $15.3 million, Convery awarded Jean Strahan hundreds of thousands of dollars in child support. The couple married in 1999.

"It pays to tell the truth, and I told the truth," Jean Strahan said in Saturday's New York Post. "I never asked for a penny more than the prenup that Michael and his lawyers wrote and made me sign. And all I ever asked for was that to be upheld

            Strahan or his attorneys probably should have read his agreement carefully. Many pre-nuptial, post-nuptial and separation agreements contain a “No-Waiver” clause that provides: “The failure of either party to insist in any one or more instances upon the strict performance of any of the terms of this Agreement by the other party shall not be construed as a waiver or relinquishment of such term or terms for the future.”   

The mere fact that Mrs. Strahahn did not seek to  enforce every provision of their agreement when the marriage was intact, in no way prevented her from seeking to enforce her contractual rights when the marriage soured.  

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CNN.com offers a great primer on the pros and cons of negotiating a pre-nuptial agreements.  The pre-nup could prevent litigation in the event the marriage ends in divorce.  On the other hand, a difficult negotiation may end the relationship before a marriage takes place.

I have excerpted the article here:

Pre-nuptial agreements, are no longer an exclusive financial risk management tool for Hollywood couples.  Having seen what can happen when a high-profile relationship fails, increasing numbers of less famous couples are known to be opting for written agreements to protect the financial assets each partner brings to the relationship.

Some of the advantages of such an agreement are: to protect your separate property; support your estate plan; it defines what property is considered marital property or community property; it reduces conflicts and saves money if you divorce; it clarifies special agreements between you, and it establish procedures and ground rules for deciding future matters.

But, of course a prenup is not romantic.

As the artice points out, "Being engaged conjures up images of candlelit dinners and walks in the moonlight. Although marriage is a financial partnership as well as a romantic one, if you feel that discussing something as mundane as property and finances, as well as the possibility of divorce, will mar an otherwise beautiful time of your lives, you may not be candidates for a prenup

Pros

· A premarital agreement can protect the inheritance rights of children and grandchildren from a previous marriage.

· If you have your own business or professional practice, a premarital agreement can protect that interest so that the business or practice is not divided and subject to the control or involvement of your former spouse upon divorce.

· If one spouse has significantly more debt than the other, a premarital agreement can protect the debt-free spouse from having to assume the obligations of the other.

· If you plan to give up a lucrative career after the marriage, a premarital agreement can ensure that you will be compensated for that sacrifice if the marriage does not last.

· A premarital agreement can address more than the financial aspects of marriage, and can cover any of the details of decision-making and responsibility sharing to which the parties agree in advance.

· A premarital agreement can limit the amount of spousal support that one spouse will have to pay the other upon divorce.

· A premarital agreement can protect the financial interests of older persons, persons who are entering into second or subsequent marriages, and persons with substantial wealth.

Cons

· The agreement may require you to give up your right to inherit from your spouse's estate when he or she dies. Under the law, you are entitled to a portion of the estate even if your spouse does not include such a provision in his or her will.

· If you contribute to the continuing success and growth of your spouse's business or professional practice by entertaining clients and taking care of the home, etc., thus allowing him or her to focus on professional endeavors, you may not be entitled to claim a share of the increase in value if you agree otherwise in a premarital agreement. Under the laws of many states, this increase in value would be considered divisible marital property.

· It can be difficult to project into the future about how potential issues should be handled, and what may seem like an inconsequential compromise in the romantic premarital period may seem more monumental and burdensome in reality.

· A low- or non-wage-earning spouse may not be able to sustain the lifestyle to which he or she has become accustomed during the marriage if the agreement substantially limits the amount of spousal support to which that spouse is entitled.

· In the "honeymoon" stage of a relationship, one spouse may agree to terms that are not in his or her best interests because he or she is "too in love" to be concerned about the financial aspects and can't imagine the union coming to an untimely end.

· Starting a relationship with a contract that sets forth the particulars of what will happen upon death or divorce can engender a sense of lack of trust.

· As mentioned above, a contract can take the wind out of your emotional sails.

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