Sharon Blanchard v. Ronald Blanchard

Summary

The Maine Supreme Judicial Court affirmed a divorce judgment holding that the parties’ 1986 premarital agreement was valid and enforceable under Maine common law. The court rejected challenges based on fraud, lack of disclosure, and unconscionability, declined to enforce a later 2010 loan in the divorce proceeding because the agreement had not been amended, and upheld the judgment concerning unpaid interim spousal support.

Holdings

1. A premarital agreement executed before Maine's Uniform Premarital Agreement Act is valid under the applicable common-law principles when there is no fraud or imposition, full and complete disclosure, and adequate provisions for each spouse. When the provisions are clearly disproportionate to one spouse's wealth, a presumption of fraud arises, which the enforcing party may rebut by proving fairness, notice, understanding, and adequacy. Ronald rebutted the presumption, and the agreement was valid and enforceable.
2. The premarital agreement was not unconscionable. The evidence did not compel findings contrary to the trial court's determination that the agreement was not procedurally or substantively unconscionable.
3. The trial court did not err or abuse its discretion by declining to enforce the 2010 business loan as part of the divorce proceeding because the loan was not included in or added to the premarital agreement, which released the parties' marital rights.
4. The court would not disturb the judgment despite its failure expressly to address unpaid interim spousal support because, absent a motion for further findings, the court assumed the trial court found facts supporting a retroactive modification of the temporary support obligation, and the record did not establish an abuse of discretion.

Questions Presented

1. Whether the 1986 premarital agreement was invalid under the common-law standards applicable before Maine enacted the Uniform Premarital Agreement Act.
2. Whether the premarital agreement was unconscionable because of the circumstances of its execution or because its terms were substantively one-sided.
3. Whether the trial court was required to enforce Sharon's 2010 business loan as part of the divorce proceeding despite its omission from the premarital agreement.
4. Whether the trial court abused its discretion by not expressly ordering payment of unpaid interim spousal support.

Disposition

affirmed