In Hale v. Hale, 74 Md. App. 555, 566, 539 A.2d 247 (1988), the circuit court set aside a separation agreement entered into by spouses on the ground, among others, that the husband and wife were in a confidential relationship and the agreement did not fairly distribute the parties' considerable assets. The couple had been married for 17 years. The wife had attended a community college for one year; had limited business experience, functioning in a merely ministerial role with her husband's company; managed the couple's household only by following a budget given to her by her husband; did not have a bank account before the couple separated; only had signed documents relating to the husband's business because he had directed her to; and was not well physically or emotionally. She had signed a separation agreement that her husband presented to her that was prepared by the husband's lawyer (even though she thought the lawyer was representing her) and upon reassurances by the husband that if she signed the agreement they would reconcile. The Court affirmed the ruling of the circuit court on the ground that the non-clearly erroneous factual findings established that the husband long had occupied a position of dominion and control over the wife in financial and business matters; that he thus was in a confidential relationship with her; that she was entitled, based on that relationship, to trust that he would take care of her, even in the creation of a separation agreement; and, with the confidential relationship established as a matter of fact, the husband had failed to satisfy his burden of showing that the separation agreement was fair to his wife. (In fact, the agreement gave her only a tiny fraction of the marital estate.) Hale v. Hale, was an appeal by a husband whose wife had brought an action against him seeking rescission of a separation agreement in upholding the trial judge's finding that the husband was the dominant party, the Courtadopted the holding in Bell v. Bell, 38 Md. App 10, 379 A.2d 419 (1977) that the existence of a confidential relationship between husband and wife is a question of fact.