In In re Marriage of Benson (2005) 36 Cal.4th 1096, a case involving a post-marital agreement governed by Family Code section 852, the court rejected an argument by one of the parties that an earlier appellate opinion regarding premarital agreements supported his position regarding the agreement at issue there. In so doing, the court noted that there had been "recent changes linking the voluntariness of premarital contracts to the availability of independent counsel" and then cited the new section 1615(c) as the statute it had in mind. (Benson, supra, at p. 1110, emphasis added.)