In re Estate of Greiff
New York Court of Appeals
703 N.E.2d 752 (1998)
Helen (plaintiff) and Herman Greiff, married at ages 65 and 77 respectively, signed reciprocal prenuptial agreements waiving their surviving-spousal rights against each other's estates; Herman's will ultimately left his entire estate to his children from a prior marriage (defendants). After Herman's death, Helen sought a spousal share, and the surrogate's court invalidated the prenuptial agreements, finding Herman had exerted undue influence over Helen and acted in bad faith in having them executed; the appellate division reversed, and Helen appealed.
Whether a spouse challenging a prenuptial agreement is entitled to an automatic presumption of fraud (shifting the burden to the agreement's proponent to disprove it), given the special relationship of trust between engaged or married parties, or must instead first establish a particularized inequality before any burden shifts.