Lewis, W. v. Lewis, C.
2020 Pa. Super. 140
| Pa. Super. Ct. | 2020Background
- William D. Lewis (Husband) and Cameron H. Lewis (Wife) married soon after meeting; Wife became a stay‑at‑home parent and the marriage turned abusive and controlling.
- By late 2016 Husband had manipulated Wife’s psychiatric treatment and medication; Wife attempted suicide and was hospitalized in December 2016.
- Husband represented a post‑nuptial settlement agreement as a harmless “paper trail” for his employer and, on January 13, 2017 immediately after a psychiatrist visit (with Husband attending), had Wife notarize and sign the agreement; Wife alleges she was medicated, fearful, threatened (including that she would never see her child if she consulted counsel), and did not meaningfully review the document.
- In July 2018 a PFA proceeding found Husband to be the abuser; Wife obtained exclusive possession of the marital home. Husband then filed to enforce the January 2017 settlement and to hold Wife in contempt.
- After a two‑day hearing the trial court invalidated the settlement for duress and fraud; Husband appealed.
- The Superior Court affirmed: it accepted the trial court’s credibility findings and held the record supports invalidation for duress (the court did not need to resolve fraud on appeal).
Issues
| Issue | Plaintiff's Argument (Husband) | Defendant's Argument (Wife) | Held |
|---|---|---|---|
| Whether the post‑nuptial settlement (1/13/17) was invalid for duress | Record does not support trial court’s credibility findings; even if true, facts do not meet legal standard for duress | Wife signed under threatened/impending harm, chronic domestic control, heavy medication, recent suicide attempt, and inability to consult counsel | Affirmed: trial court’s credibility findings supported; Wife rebutted presumption of "ordinary firmness"; threats, abuse, medication, and lack of opportunity to consult counsel satisfied duress, making the agreement voidable |
| Whether the agreement was void for intentional fraud in the inducement | (Implicit) No fraud; the agreement was validly executed | Husband misrepresented the document as benign employment/estate paperwork to induce signature | Not reached on appeal (trial court found fraud as an alternative ground, but the Superior Court disposed of the case on duress) |
| Whether the trial court showed bias or acted improperly | Trial judge exhibited bias by relying on prior proceedings, admonishing Husband, and independently researching the notary | Any adverse remarks reflect credibility determinations; objections were waived or lacked merit | Mostly waived for failure to raise below; where addressed, no abuse of discretion shown; independent inquiry into notary employment was error of judgment but harmless to outcome |
Key Cases Cited
- Carrier v. William Penn Broadcasting Co., 233 A.2d 519 (Pa. 1967) (defines legal duress and presumption of ordinary firmness)
- Simeone v. Simeone, 581 A.2d 162 (Pa. 1990) (marital agreements governed by contract principles; duress negates mutual assent)
- Adams v. Adams, 848 A.2d 991 (Pa. Super. 2004) (duress claims between spouses; courts reluctant to void marital agreements absent clear proof)
- Stoner v. Stoner, 819 A.2d 529 (Pa. 2003) (appellate review standards and relevance of marital contract principles)
- Stackhouse v. Zaretsky, 900 A.2d 383 (Pa. Super. 2006) (appellate court will not reweigh trial court credibility determinations)
- Lugg v. Lugg, 64 A.3d 1109 (Pa. Super. 2013) (pressure and negotiation tactics short of coercion do not automatically establish duress)
- Green v. Green, 69 A.3d 282 (Pa. Super. 2013) (party who produces a document at trial cannot later challenge the court’s consideration of it on appeal)
- C.H.L. v. W.D.L., 214 A.3d 1272 (Pa. Super. 2019) (prior PFA litigation in the same court finding husband abused judicial process; part of factual background relied on by trial court)
- In re Ratony's Estate, 277 A.2d 791 (Pa. 1971) (party seeking to avoid an executed agreement bears burden of clear and convincing proof)