Keyes v. Keyes
351 P.3d 90
| Utah Ct. App. | 2015Background
- Husband and Wife signed a premarital agreement before a 17‑year marriage providing each would retain separate ownership of listed assets; Husband’s exhibit expressly listed proceeds and increases in value from his family landscaping business.
- Trial court found the premarital agreement unenforceable under Utah’s Premarital Agreement Act, concluding Wife proved fraud because Husband failed to disclose financial information, Wife did not waive disclosure, and Wife lacked knowledge of Husband’s finances.
- Because the court deemed the agreement unenforceable, it treated inventory acquired by Husband’s business during the marriage as marital property and awarded Wife one‑half of Husband’s interest in inventory ($115,266 of a $461,064 valuation).
- The court ordered Husband to pay $1,928/month alimony (duration equal to the marriage) after imputing income to both parties (Husband $2,627/mo; Wife imputed $1,257/mo), aiming to equalize their monthly shortfalls.
- On appeal Husband challenged: (1) the court’s failure to make an independent fraud finding before invalidating the premarital agreement and (2) the inventory award as lacking adequate factual findings; he also argued the alimony award was an abuse of discretion and facially inequitable.
Issues
| Issue | Husband's Argument | Wife's Argument | Held |
|---|---|---|---|
| Enforceability of premarital agreement (fraud requirement) | Trial court erred by not making an independent fraud finding; the three statutory subsidiary factors do not automatically establish fraud | Agreement unenforceable because no reasonable disclosure, no waiver, and Wife lacked knowledge | Reversed and remanded: trial court must separately determine whether the agreement was "fraudulent when executed" under the statute; subsidiary factors are relevant but do not substitute for a fraud finding |
| Waiver of disclosure under the premarital agreement | Husband: Agreement’s language (¶10) constituted a written waiver of further disclosure | Wife: No valid waiver; insufficient disclosure | Waiver argument not considered on appeal — unpreserved because Husband failed to raise waiver below; remand limited to fraud inquiry |
| Characterization/distribution of business inventory | Husband: Inventory purchased with business (his separate property) and award to Wife lacks adequate findings | Wife: Contributed (helped obtain racks, encouraged diversification) supporting marital interest | Remanded conditionally: trial court’s findings about inventory were legally inadequate; if agreement is not enforced, court must either provide detailed subsidiary findings explaining why inventory is marital/why Wife is entitled to one‑half or reconsider the distribution |
| Alimony amount and method (equalization of poverty) | Husband: Award is abuse of discretion and leaves him unable to meet basic needs; court imputed Wife’s income without adequate support | Wife: Needs and imputed income supported by her declarations; equalization appropriate to share hardship | Vacated and remanded: alimony award is facially inequitable and court’s findings (Wife’s earning capacity, imputation, and effect on Husband’s basic needs) are unsupported or inadequate; court must reassess and explain its reasoning |
Key Cases Cited
- Beesley (In re Estate of Beesley), 883 P.2d 1343 (Utah 1994) (premarital agreements require high degree of good faith and candor)
- Reese v. Reese, 984 P.2d 987 (Utah 1999) (premarital agreements valid absent fraud, coercion, or material nondisclosure)
- Atkinson v. IHC Hosps., Inc., 798 P.2d 733 (Utah 1990) (definition of fraud: false representation of existing material fact knowingly or recklessly made to induce reliance causing detriment)
- Rappleye v. Rappleye, 855 P.2d 260 (Utah Ct.App. 1993) (trial court must provide adequate findings to show how property distribution conclusions were reached)
- Stonehocker v. Stonehocker, 176 P.3d 476 (Utah Ct.App. 2008) (trial court has broad discretion in property division; reversal requires clear abuse)
- Dahl v. Dahl, 345 P.3d 566 (Utah 2015) (framework for classifying marital vs. separate property and steps for equitable distribution)
- Mark v. Mark, 223 P.3d 476 (Utah Ct.App. 2009) (trial court must make detailed findings on statutory alimony factors)