Gabaig v. Gabaig
In Gabaig v. Gabaig, 717 P.2d 835, 841 (Alaska 1986) the trial court found that the husband actively discouraged the wife from consulting with an attorney and repeatedly threatened divorce, and therefore there was no arm's length bargaining.
It further concluded that the husband did not fully disclose his assets; therefore, there was no full disclosure. While the husband's repeated threats of divorce played some role in the court's decision, the court also had evidence of the husband's active dissuasion of the wife's need to seek counsel regarding the agreement.
Furthermore, the Gabaig Court had to deal with the husband's unwillingness to disclose all his assets.