Stewart v. Stewart, 41 A.3d 401

Married Feb 1984, separated Apr 2005, permanently separated Nov 2005, one child born 1991.
Sept 28, 2005, the parties signed a Marital Property Settlement Agreement drafted by Wife's counsel.
Alimony provision stated: $1,200 per month for the life of Wife, terminating only at Wife's death.
In 2005–2006 Husband learned Delaware law terminates alimony on remarriage or cohabitation unless otherwise agreed.
2006 divorce decree incorporated the Agreement; Husband later sought modification based on Wife's cohabitation.
Family Court reformed the alimony provision to terminate on death or remarriage/cohabitation of the recipient; judgment dismissing Wife's petition affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the alimony reform was proper based on unconscionability	Stewart argues the provision was unconscionable and overreaching	Stewart contends the original contract was valid and not unconscionable	Yes; the court reformed the provision and held it unconscionable as executed.
Whether the contract was tainted by undue influence or lack of counsel	Stewart asserts Husband lacked counsel and was pressured	Stewart contends both parties understood the terms; no undue influence shown	Yes; the record showed overreaching and lack of informed consent by Husband.
Whether laches barred Wife's enforcement action	Stewart argues timely enforcement of alimony	Stewart argues laches was not applicable given ongoing proceedings	Rejected; laches not dispositive to invalidate modification.

Robert O. v. Ecmel A., 460 A.2d 1323 (Del. 1983) (confidential relationship in contract validity and equitable considerations)
Graham v. State Farm Mut. Auto. Ins. Co., 565 A.2d 908 (Del. 1989) (connotes standards for unconscionability)
Brown v. Div. of Family Servs., 14 A.3d 507 (Del. 2011) (context for review of family court decisions and standards)