In the Matter of the Estate of Karl A. Kloster, 20-1245

Sandra Hawks met Karl Kloster in 2007, moved to his home in Knoxville, and they married in June 2008.
The day before the wedding Sandra signed a premarital agreement prepared by Karl’s attorney; it waived inheritance/distributive-share/elective-share rights.
The agreement gave Sandra a life use of the residence (until remarriage or one year of absence), payment of utilities/maintenance/taxes by the estate, and a $400/month allowance; Karl’s attached financial statement showed a net worth over $1.2 million; Sandra’s statement was vague.
Sandra was told she could consult independent counsel but declined; she signed at the attorney’s office and received a copy.
In 2019 Sandra filed for dissolution; Karl died before divorce concluded. Sandra sought an elective share as surviving spouse; the district court held the premarital agreement enforceable, denied the elective share, and awarded a limited spousal allowance. Sandra appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the premarital agreement is procedurally unconscionable	Sandra: Agreement was presented one day before the wedding and procured by unequal bargaining; temporal proximity + her lack of sophistication made it unconscionable	Estate/Kloster: Sandra had opportunity to read and consult counsel, the agreement’s language was not technical, and she knowingly declined counsel	Court: Temporal proximity alone insufficient; no other indicia of procedural unconscionability; agreement enforceable
Whether Sandra’s decision was informed by fair and reasonable financial disclosure	Sandra: Karl’s disclosure was inadequate; she lacked adequate knowledge of his finances so the waiver is unenforceable	Estate/Kloster: Karl attached a financial statement and Sandra had general knowledge of his assets (farmland, rentals, antiques); no evidence of concealment	Court: Disclosure was "fair and reasonable" and Sandra had adequate knowledge; she failed to prove nondisclosure

In re Estate of Spurgeon, 572 N.W.2d 595 (Iowa 1998) (valid premarital agreement can waive surviving spouse’s elective-share claim)
In re Estate of Myers, 825 N.W.2d 1 (Iowa 2012) (equitable trial standard and de novo appellate review for elective-share disputes)
In re Marriage of Shanks, 758 N.W.2d 506 (Iowa 2008) (factors relevant to procedural unconscionability and burden on challenger)
In re Marriage of Spiegel, 553 N.W.2d 309 (Iowa 1996) ("fair and reasonable" disclosure requires general knowledge, not precise valuations)