The motion to set aside the prenuptial agreement was heard in December 2009. The court heard testimony from the parties, their respective witnesses, and their attorneys and ruled that the former wife signed the prenuptial agreement under duress and declared it voidable, making it subject to the equitable defenses of ratification and laches. See Bakos v. Bakos, 950 So.2d 1257, 1259–60 (Fla. 2d DCA 2007). Thereafter, the court denied the motion to set aside the prenuptial agreement because the former “wife's inaction” after being notified by her attorney of the inequity of the agreement operated as a ratification of the agreement. The court also found that the former wife's more than six-year delay in challenging the prenuptial agreement constituted laches.
These factual circumstances, considered in tandem with the other evidence of record discussed at length in the panel opinion, were more than sufficient to support the decision by the trial court. See Bakos v. Bakos, 950 So.2d 1257, 1259 (Fla. 2d DCA 2007); Ziegler v. Natera, 279 So.3d 1240, 1243 (Fla. 3d DCA 2019); Hjortaas v. McCabe, 656 So.2d 168, 170 (Fla. 2d DCA 1995); Paris v. Paris, 412 So.2d 952, 954 (Fla. 1st DCA 1982)
These factual circumstances, considered in tandem with the other evidence of record discussed at length in the panel opinion, were more than sufficient to support the decision by the trial court. See Bakos v. Bakos, 950 So. 2d 1257, 1259 (Fla. 2d DCA 2007) ; Ziegler v. Natera, 279 So. 3d 1240, 1243 (Fla. 3d DCA 2019) ; Hjortaas v. McCabe, 656 So. 2d 168, 170 (Fla. 2d DCA 1995) ; Paris v. Paris, 412 So. 2d 952, 954 (Fla. 1st DCA 1982) ; Flaherty v. Flaherty, 128 So. 3d 920, 923 (Fla. 2d DCA 2013) ; Lutgert v. Lutgert, 338 So. 2d 1111, 1116 (Fla. 2d DCA 1976) ; see also Garcia v. Soto, 337 So. 3d 355, 363 (Fla. 4th DCA 2022) (Artau, J., dissenting) (alteration in original) (citations omitted) (quoting Bueno v. Workman, 20 So. 3d 993, 998 (Fla. 4th DCA 2009) ) (" Bueno explained that ‘it would be inappropriate’ to ‘employ the tipsy coachman rule where [the] lower court [had] not made factual findings on [the fraud] issue[.]’
We have jurisdiction pursuant to Florida Rule of Appellate Procedure 9.130(a)(3)(C)(iii) c. "We review a trial court's determination of the voidability of an antenuptial agreement for competent, substantial evidence." Bakos v. Bakos, 950 So. 2d 1257, 1259 (Fla. 2d DCA 2007) (citing Simzer v. Simzer, 514 So. 2d 372, 373 (Fla. 2d DCA 1987) ). "[T]he findings of the trial court come to this court clothed with a presumption of correctness[,] and will not be disturbed absent a showing that there was no competent evidence to sustain them." Baker v. Baker, 394 So. 2d 465, 466 (Fla. 4th DCA 1981) (citations omitted); see also Schreiber v. Schreiber, 795 So. 2d 1054, 1057 (Fla. 4th DCA 2001) ; Snedaker v. Snedaker, 660 So. 2d 1070, 1072-73 (Fla. 4th DCA 1995).
Contingent fee agreements that do not comply with the regulations are "void as against the public interest." Chandris, S.A. v. Yanakakis , 668 So.2d 180, 181 (Fla. 1995) ; see also Bakos v. Bakos , 950 So.2d 1257, 1259–60 (Fla. 2d DCA 2007) (noting that a void contract cannot be ratified). Even if the agreement at issue here was merely voidable, Appellant did not ratify the agreement.
A postnuptial agreement is subject to interpretation like any other contract. See, e.g., Bakos v. Bakos, 950 So.2d 1257, 1259–60 (Fla. 2d DCA 2007). “The trial court's interpretation of a contract is a matter of law subject to a de novo standard of review.” See Chipman v. Chipman, 975 So.2d 603, 607 (Fla. 4th DCA 2008).
A postnuptial agreement is subject to interpretation like any other contract. See, e.g., Bakos v. Bakos, 950 So.2d 1257, 1259-60 (Fla. 2d DCA 2007). The trial court's interpretation of a contract is a matter of law subject to a de novo standard of review.