336 A.3d 321
Vt.2025Background
- Danielle Lacroix and Peter Rysz married in 2015 after negotiating a prenuptial agreement primarily to protect Rysz's pre-marital property and income.
- Both parties had legal counsel, made full financial disclosures, negotiated, and voluntarily signed the agreement one day before the wedding.
- The prenuptial agreement largely kept both parties' property separate and barred spousal maintenance; if the husband initiated divorce, the wife would get a mortgage-free home, but not if she filed.
- In 2019, Lacroix filed for divorce after leaving the marital home and obtaining a relief from abuse order.
- The family court set aside the prenuptial agreement as unconscionable and granted Lacroix substantial property and monetary awards; Rysz appealed this ruling.
Issues
| Issue | Lacroix's Argument | Rysz's Argument | Held |
|---|---|---|---|
| Enforceability of Prenuptial Agreement | Unenforceable as unconscionable and unfair; circumstances and substantive terms violated public policy | Agreement was voluntarily entered, with counsel and disclosure; court applied incorrect standard of unconscionability | Trial court applied wrong legal standard; reversed and remanded for alternative grounds |
| Quashing Subpoenas | Subpoenas to family members irrelevant; affidavits showed lack of relevant financial info | Needed family financial records to challenge possible undisclosed assets | Not decided due to remand |
| Calculation of Marriage Length | N/A | Court erred in stating marriage lasted 8 years | Not reached—remanded |
| Constructive Divorce Filing | Husband’s behavior forced her to file for divorce, entitling her to benefits as if he filed | Denied responsibility; agreement terms clear | Remanded for fact-finding |
Key Cases Cited
- Bassler v. Bassler, 156 Vt. 353 (Vt. 1991) (establishes prenuptial enforceability requirements including fair disclosure, voluntariness, fairness, and unconscionability)
- Gamache v. Smurro, 180 Vt. 113 (Vt. 2006) (general principles for contract interpretation in family law)
- Stalb v. Stalb, 168 Vt. 235 (Vt. 1998) (upholding prenuptial agreements that leave parties in their pre-marriage financial position)
- Padova v. Padova, 123 Vt. 125 (Vt. 1962) (contracts binding unless fraud/unconscionability proven at execution)