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In re Marriage of Bonds

Also known as: Bonds v. Bonds

The 2000 California Supreme Court case upholding Barry Bonds's prenup. The public outcry prompted California to enact §1615(c), the modern 7-day rule and independent-counsel requirement.

Barry Bonds and his fiancée Sun signed a prenup the day before their 1988 wedding. Sun had limited English and no independent counsel. The California Supreme Court enforced the prenup in 2000 under then-existing law. The public response, combined with criticism from family-law practitioners, led the Legislature to enact Cal. Fam. Code §1615(c) in 2002 — codifying the 7-day rule, the independent-counsel requirement, and specific voluntariness factors. A prenup like Bonds' would be automatically unenforceable in California today.

Related terms

  • Seven-Day Rule — California's statutory requirement that at least seven calendar days pass between presenting the final prenup and signing it. Agreements signed inside the window are automatically unenforceable.
  • Independent Counsel — Each spouse having their own attorney during prenup negotiation. Required by statute in California; heavily weighted in every other state.
  • Voluntariness — The requirement that both spouses signed the prenup of their own free will, without fraud, duress, coercion, or undue influence.

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