Background
Yuancong Zhang and Stuart M. Chen met while Zhang was living in China. Before their 2015 marriage, Chen had an attorney prepare an antenuptial agreement intended to preserve his assets for his two children, including a permanently disabled child requiring lifelong care. The agreement generally kept each party’s property separate and waived rights to appreciation, maintenance, support, and death benefits. Chen gave Zhang the English-language agreement approximately six months before she signed it and repeatedly advised her to have it translated and explained.
Zhang entered the United States on a K-1 fiancé visa and signed the agreement eleven days after arriving in Kentucky. Chen’s disclosed assets exceeded $1 million, while Zhang’s were approximately $39,000. After Chen petitioned for dissolution in 2023, Zhang challenged the agreement as the product of duress and inadequate disclosure and as unconscionable. The Madison Family Court upheld the agreement, enforced it in the dissolution decree, and did not award Zhang maintenance.
The Court’s Holding
The Court of Appeals affirmed. It held that substantial evidence supported the family court’s finding that Zhang had ample time, resources, and ability to obtain a translation or explanation but chose not to do so. Under Kentucky law, a person who signs a contract is generally presumed to know its contents, and a person unable to read it has a duty to obtain reliable assistance before signing. Conditioning the marriage on execution of a lawful antenuptial agreement also did not constitute duress.
The court further upheld the determination that enforcing the agreement and its maintenance waiver was not unconscionable. Although the parties remained financially unequal, that disparity was essentially the same as when they signed the agreement, and neither had materially increased their wealth during the marriage. Evidence also indicated that Zhang had obtained employment, may have retained assets in China, and could pursue Chen’s federal immigration-sponsorship obligation in a separate action. The court emphasized that Zhang had expressly declined to pursue that federal obligation in the family-court proceedings and therefore had not preserved a request for its enforcement there.
Key Takeaways
- A party who signs an antenuptial agreement ordinarily cannot avoid it merely because she did not read or understand its language when she had an opportunity to obtain translation or assistance.
- Refusing to marry unless an antenuptial agreement is signed does not, by itself, constitute duress under Kentucky law.
- A substantial financial disparity does not automatically make an antenuptial agreement unconscionable, particularly when the disparity was disclosed and has not materially changed.
- A federal immigration sponsor’s support obligation may exist independently of state-law maintenance rights and may be pursued in a separate action.
Why It Matters
The opinion illustrates Kentucky courts’ willingness to enforce antenuptial agreements when the challenging party had sufficient time and opportunity to obtain translation, legal advice, or other assistance before signing. It also confirms that courts assess unconscionability at enforcement by examining changed circumstances, not merely whether the original bargain was financially unfavorable.
For family-law practitioners representing sponsored immigrants, the decision underscores the need to distinguish state maintenance claims from rights arising under a federal immigration affidavit of support—and to preserve each claim in the appropriate proceeding.