Duffy v. Duffy
Court of Appeals of the District of Columbia
881 A.2d 630 (D.C. 2005)
Brian and Joan Duffy (defendant and plaintiff) negotiated a separation agreement that Joan drafted as a letter to her lawyer, including Brian's child-support obligations; both signed the letter, intending it to be formalized later by counsel and reviewed by Brian's lawyer. That formal version was never signed, but Brian complied with the letter's terms for over a year before unilaterally cutting his payments. Joan sued to enforce the letter agreement; the trial court found it enforceable, and Brian appealed, arguing it should have included a provision letting his support obligation drop if, for example, he lost his job.
Whether, absent fraud, duress, concealment, or overreaching, a separation agreement is presumptively valid and binding regardless of how ill-advised a party may have been in executing it.