Bates v. Bates
The Third District affirmed a non-final order invalidating a prenuptial agreement, holding for the first time in Florida that "coercion" is a distinct, broader ground than "duress" under Casto and section 61.079(7). Although there was no competent substantial evidence of duress (no threat to expose the wife's abortion for the husband's pecuniary gain), there was competent substantial evidence of coercion where the husband falsely told the 18-year-old, non-English-speaking wife that signing was required for her U.S. immigration, presented the agreement the day before the wedding, and exploited her post-abortion vulnerability.
Key facts
- Husband and wife with a prenuptial agreement; wife challenged the agreement's validity in family court.
- Trial court invalidated the prenuptial agreement, finding the husband coerced the wife into signing by misrepresenting that execution was required for U.S. immigration, presenting the agreement the day before the wedding, and exploiting her vulnerability after a recent abortion.
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Why it matters
This is the first Florida opinion to define "coercion" as an independent and broader ground for invalidating a prenuptial agreement under Casto and section 61.079(7), separating it from the more demanding duress… — full analysis with a trial
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