In re the Marriage of Curtis

Dr. Phillip Curtis, Jr., and Roberta Phillips entered into a property settlement agreement. The agreement became part of the dissolution decree. Ms. Phillips *194hired a new lawyer and moved to vacate the property settlement before presentment of the decree. The court denied her motion. She appeals, and argues that the court should have applied the factors set forth in RCW 26.09.080 (considerations for the disposition of community property and liabilities) before accepting their negotiated property settlement.

Absent fraud, overreaching, or collusion, the courts will not set aside a property…