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James Robert Brantley, Sr.v.Cyd Oglesby Brantley

CourtCourt of Appeals of Georgia
Docket No.A18A0343
DecidedMay 8, 2018
Reporter286 Ga. 309
JudgesCourt of Appeals of Georgia
Tags
CivilFamily LawContract LawContract InterpretationStatutory InterpretationSummary JudgmentVacaturRemand
Case Summary

James Brantley sought to enforce an antenuptial agreement that waived both parties’ claims for alimony. The trial court refused to enforce the agreement because it concluded that Brantley had not disclosed his income within the four corners of the document. The Georgia Court of Appeals vacated that ruling. Georgia’s established test for enforcing an antenuptial agreement requires consideration of full and fair financial disclosure, voluntariness, unconscionability, and whether enforcement would be fair and reasonable. The appellate court held that the trial court had applied an incorrect legal standard by refusing to consider evidence outside the agreement, including financial disclosures connected with the couple’s mortgage application, the parties’ relationship, and their knowledge of each other’s financial circumstances. The court did not decide whether the evidence ultimately established adequate disclosure. It remanded for the trial court to reconsider enforceability under the correct standard.

Opinion

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