Property

Button v. Button — Study Notes

Button v. Button, 131 Wis. 2d 84, 388 N.W.2d 546 (1986)

Study notes for Button v. Button: professor notes, cold call prep, exam angles, and memory aids.

Prenuptial agreements are unenforceable if enforcing them leads to an unjust result due to unforeseen changes in circumstances.
Professor Notes

Button v. Button addresses critical issues surrounding the enforceability of prenuptial agreements, especially in light of changed circumstances during the marriage. Professors often highlight that this case illustrates the balance between upholding personal agreements and ensuring fair outcomes in family law. The Wisconsin Supreme Court's decision emphasizes the principle that agreements made in anticipation of marriage must retain fairness and equity even upon dissolution, aligning with broader equitable principles in property law. Professor discussions may also touch on how societal standards and legal precedents affect individual agreements made under changing circumstances.

Moreover, professors may focus on the implications of this decision for future prenuptial agreements, creating awareness that while parties have the freedom to contract, that freedom is not absolute when it comes to fundamental fairness, particularly concerning spousal equity and welfare. This case serves as a cautionary tale about the necessity of including provisions that can adapt to future unforeseen circumstances within such agreements.

Cold Call Prep
  1. 1Explain the main facts of Button v. Button.
  2. 2What was the central issue in Button v. Button?
  3. 3How did the court rule regarding the enforceability of the prenuptial agreement?
  4. 4What were the changes in circumstances that influenced the court's ruling?
  5. 5Discuss the implications of this case on future prenuptial agreements.
  6. 6How does this case relate to public policy in family law?
  7. 7What could parties do to make a prenuptial agreement more enforceable?
Mnemonic Device

Prenup Flex: Be Fair or Beware!

Distinguish From
CaseDistinction
In re Marriage of DormanIn Dorman, the court enforced a prenuptial agreement because the circumstances did not change significantly, unlike in Button.
Kratzer v. KratzerIn Kratzer, the enforceability was upheld as the terms were still deemed fair, demonstrating a stable framework not altered by unforeseen factors.
Sullivan v. SullivanSullivan involved a mutual waiver with agreement adherence, which contrasted with Button’s changed circumstances demanding reevaluation of equitable distribution.
Policy Arguments

For the Rule

Enforcement of prenuptial agreements should depend on fairness and justice at the time of dissolution, ensuring that agreements remain equitable despite changing circumstances.

Against the Rule

Allowing flexibility in enforcing prenuptial agreements could undermine the sanctity of contracts, leading parties to second-guess their commitments.

Class Discussion Points
  • How do changes in financial circumstances of both parties impact the enforceability of prenuptial agreements?
  • What role does public policy play in determining the outcome of property distribution in divorce cases?
  • Should prenuptial agreements include clauses that specifically address the possibility of unforeseen changes during marriage?
Exam Angle

This case often appears on law exams in the context of prenuptial agreements and the shifting dynamics of marital property law, emphasizing the need for both parties to anticipate changes that can affect enforceability. Students should be prepared to analyze the implications of equitable distribution principles alongside contractual freedom.

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