Hawaii Supreme Court

Patricia Ann Lewis, Respondent-Appellee v. Daniel Harbert Lewis, Petitioner-Appellant; and Thomas Vyn Reese, Sr…

January 22, 198869 Haw. 497

Summary

The court held that Hawaii law governs the enforceability of both premarital agreements because Hawaii had the most significant relationship to the parties and the subject matter. It ruled that premarital agreements are enforceable as contracts unless a party did not enter them voluntarily or the agreement is unconscionable, but it required further findings regarding those issues in Lewis. In Reese, the court upheld the agreement's validity and directed strict enforcement in dividing property, while vacating and remanding both property dispositions for further proceedings.