Buettner v. Buettner

John Buettner (plaintiff) and Stella Buettner (defendant) entered into a prenuptial agreement in contemplation of marriage. The prenuptial agreement governed the division of property in the event of divorce, required John and Stella to execute reciprocal wills giving each other substantial bequests, and protected John’s right to retain his valuable separate property. Specifically, in the event of divorce, Stella would retain ownership of the marital residence and would receive $30,000 payable in monthly installments over a period of five years. John and Stella married in December 1970, and John filed for divorce in April 1971. During the short marriage, John severely beat Stella twice to the point that she required surgery and hospitalization. In his divorce petition, John sought to invalidate the prenuptial agreement, arguing that (1) it was the product of fraud and misrepresentation and (2) it was void as contrary to public policy because the post-divorce property-division terms were so generous that they induced Stella to seek divorce. John alleged without corroborating evidence that he sought divorce because Stella mistreated him. Stella challenged, arguing that the prenuptial agreement should be upheld to preserve Stella and John’s mutual agreement regarding property division upon divorce. The trial court granted the divorce and invalidated the prenuptial agreement, holding that a prenuptial agreement that included terms dividing property upon divorce was void as contrary to public policy. The trial court awarded Stella substantially less than she would have been entitled to receive under the terms of the prenuptial agreement. Stella appealed.