Gross v. Gross
The 1984 Ohio Supreme Court case establishing the three-part test that still controls Ohio prenup enforcement, including the two-look rule.
Gross set Ohio's three-part enforceability test: voluntary execution, full disclosure or knowledge, and not unconscionable at execution OR at enforcement. The two-look element — review at enforcement, not just at signing — places Ohio among the stricter states for one-sided prenups.
Related terms
- Two-Look Rule — The doctrine in some states (notably Massachusetts and Ohio) requiring that a prenup be fair both at signing AND at the time of enforcement.
- Unconscionability — A judicial doctrine that allows courts to refuse to enforce contracts that are shockingly unfair. The second pillar (with voluntariness) of prenup invalidation.
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