Simeone v. Simeone: How Pennsylvania Courts View Prenuptial Agreements

A prenuptial agreement can offer clarity and protection for both spouses. On the other hand, it can also spark fierce disputes when the marriage ends. In Pennsylvania, the landmark case of Simeone v. Simeone defined how courts evaluate these agreements. The case remains the foundation for modern Pennsylvania family law on prenuptial agreements.

Background of the case

In the Simeone case, the husband was a 39-year-old neurosurgeon who earned roughly $90,000 per year and possessed roughly $300,000 in assets. The wife, on the other hand, was a 23-year-old nurse who was not employed at the time of the marriage. The day before their wedding, the husband’s attorney presented the wife with a prenuptial agreement that waived her right to support beyond $25,000 if the couple divorced. The wife signed the contract on the eve of her wedding without retaining separate legal counsel. The marriage took place the following day.

The marriage later dissolved. The wife, presented with an onerous prenup, challenged the validity of the agreement. She argued that she had not been given adequate time to review the document and did not have a lawyer look over the document before signing. For that reason, enforcing the agreement would be fundamentally unfair.

The Pennsylvania Supreme Court’s decision

The Supreme Court took the opportunity to use Simeone to modernize Pennsylvania’s approach to prenuptial agreements. Prior to the decision, courts generally examined whether such agreements were “reasonable” or “fair.” The case rejected that paternalistic approach and emphasized that adults have the right and responsibility to understand and be bound by the contracts that they sign.

The court held that a prenuptial agreement is a contract just like any other, and should be enforced unless the challenging party can prove (by clear and convincing evidence) that it was not entered into voluntarily. In other words, fraud, misrepresentation, or duress occurred during the signing of the agreement that made it invalid. The court made it clear that a lack of legal counsel or representation was concerning, but not enough to void the agreement. In other words, this case shifted the focus away from whether the agreement was “fair” and toward whether it was knowingly and voluntarily entered into when signed.

The impact of Simeone

The Pennsylvania courts continue to apply the Simeone case in courts of law. Parties are presumed to understand and accept the legal consequences of signing an agreement. Today, this framework is enforced and codified in 23 Pa.C.S. § 3106. This rule governs the enforceability of prenuptial agreements today.

Talk to a Philadelphia, PA, Prenuptial Agreement Lawyer Today

The Law Offices of Lauren H. Kane represent the interests of Philadelphia residents who want to draft a prenuptial agreement. Call our Philadelphia family lawyers today to schedule an appointment, and we can begin taking those next steps right away.

Source:

casebriefs.com/blog/law/family-law/family-law-keyed-to-weisberg/getting-married/simeone-v-simeone/