Kline v. Kline
Pennsylvania Supreme Court
57 Pa. 120 (1868)
Gabriel Kline and Ann Hendricks (defendant) were married for 17 years. On the night before their wedding, Gabriel read an antenuptial agreement to Ann. An antenuptial agreement is a written agreement between parties who are about to marry, specifying the parties’ property rights during the marriage and their distribution in the event of dissolution of the marriage. Ann could not speak English. The agreement left Ann with $40 per year and a mere life estate in portions of the family home. A life estate is an interest in real property that is held only for the life of the holder and in which the holder possesses no future interest beyond her lifetime. Although a life estate is transferrable, the interest remains limited to the lifetime of the original holder of the life estate, and the future interest passes to the remaindermen at the life-estate holder’s death. Following Gabriel’s death, Samuel Kline and Dillman Bean (plaintiffs) sought to use the antenuptial agreement to prevent Ann from claiming a share of Gabriel’s estate. Ann, then a 70-year old, childless widow, challenged the validity of the contract. Ann alleged that Gabriel was dishonest with her regarding the extent of his wealth and what she would receive upon his death. At trial, the judge gave a jury instruction that Ann was bound to exercise her good judgment in agreeing to the contract and that Gabriel was not bound to reveal to her the value of his estate. Ann challenged the jury instruction when it was given, and the instruction was assigned as error on appeal.
Rule of Law
Holding and Reasoning (Sharswood, J.)
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