Matisoff v. Dobi

The 1997 New York Court of Appeals case that struck down an otherwise valid prenup solely because it lacked the formal acknowledgment required by New York Domestic Relations Law §236(B)(3).

In Matisoff, both parties signed the prenup and its authenticity was undisputed. But the document lacked the §236(B)(3) acknowledgment — a notarial certificate with specific language. The Court of Appeals held that the requirement is mandatory and non-curable. The case is why New York family-law attorneys obsess over the acknowledgment block.