In Steele v. Steele, the New Jersey Appellate Division reviewed an appeal from the Chancery Division that enforced a marital agreement. The husband-plaintiff’s lawyer drafted a pre-marital agreement before the marriage proposal. But the plaintiff never broached the subject of the agreement with his wife until after they were married. After they wed, the wife signed what the two called a pre-marital agreement, though they were already married. The Appellative Division ruled that it was not a pre-marital agreement, but a “mid-marriage agreement”, and those agreements are generally unenforceable. Based on additional case-specific facts, the Appellate Division vacated the declaratory relief and remanded.