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Lutgert v. Lutgert

District Court of Appeal of Florida
338 So.2d 1111 (1976)
ELI5:

Rule of Law:

An antenuptial agreement will be deemed involuntary and thus unenforceable if it is grossly disproportionate and executed under coercive circumstances, which creates a presumption of undue influence or overreaching that the proponent of the agreement fails to rebut.


Facts:

  • Raymond L. Lutgert, a man of great wealth, and Muriel Stevenson became engaged approximately four weeks prior to their marriage.
  • On Monday, April 26, 1965, Raymond suggested they marry early on Friday morning, April 30, to embark on a honeymoon cruise, and his lawyers drafted an antenuptial agreement that day.
  • The following days involved a rush of wedding preparations, including purchasing wedding attire and rings, getting blood tests, and sending invitations to family and friends.
  • On the afternoon of Thursday, April 29, less than 24 hours before the ceremony, Raymond presented the antenuptial agreement to Muriel for the first time.
  • Muriel objected to signing, but Raymond insisted the wedding would be called off if she did not sign the agreement.
  • Muriel reluctantly signed the agreement just before the wedding ceremony at 12:30 a.m. on Friday, April 30.
  • The agreement stated Raymond's estate was worth approximately $3 million and limited Muriel to $1,000 per month in support and a waiver of attorney's fees in the event of separation or divorce.

Procedural Posture:

  • Raymond L. Lutgert filed a petition in a Florida trial court to dissolve his marriage to Muriel Lutgert.
  • The trial court upheld the validity of the parties' antenuptial agreement, finding that it was signed freely and voluntarily.
  • The trial court adjudicated the issues of alimony and attorney's fees in accordance with the agreement's terms.
  • Muriel Lutgert, as appellant, appealed the trial court's final judgment to the District Court of Appeal of Florida, Second District.

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Issue:

Is an antenuptial agreement, which provides a grossly disproportionate benefit to the husband, voluntarily executed and enforceable when it is presented to the prospective wife for the first time less than 24 hours before the wedding with an ultimatum that the marriage will not occur if she does not sign?


Opinions:

Majority - McNulty, Chief Judge

No. The antenuptial agreement is unenforceable because the circumstances surrounding its execution rendered it involuntary. The relationship between parties to an antenuptial agreement is one of mutual trust and confidence, requiring the highest degree of good faith and fairness. A presumption of undue influence or overreaching arises when an agreement is grossly disproportionate in favor of the dominant party. Here, the agreement was patently one-sided, limiting the wife to $1,000 per month from a multi-millionaire husband. This disproportionate benefit, combined with the coercive circumstances—presenting the agreement for the first time on the eve of the wedding with an ultimatum that there would be 'no agreement, no wedding'—created a presumption of undue influence as a matter of law. The burden then shifted to the husband to rebut this presumption, which he failed to do. The fact that the wife spoke to the husband's lawyers or had been married before does not overcome the coercive effect of the ultimatum delivered at the last minute.



Analysis:

This case establishes that the voluntariness of an antenuptial agreement can be vitiated by the circumstances of its presentation and execution, not just its substantive terms or the adequacy of financial disclosure. It creates a significant precedent by formalizing a burden-shifting framework: if an agreement is grossly disproportionate and executed under coercive conditions (like a last-minute ultimatum), a presumption of undue influence arises. This holding provides a crucial defense for parties challenging prenuptial agreements signed under duress, emphasizing that 'fairness' in this context includes a reasonable time to reflect and seek independent counsel, free from the pressure of a pending wedding.

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