This section contains the nature of the case and procedural background.

H and W sought a dissolution of their marriage. The petition included a separation agreement signed by both parties. W gave custody of the couple's two sons to H and the couple's daughter to W. W's annual income was less than half of H's. The agreement stated that W would not receive spousal support. The agreement did not require either party to pay child support. The trial judge extensively questioned W about the terms of the separation agreement. She stated that she consented to the terms. Despite having 'some distinct reservations' about the agreement, the trial judge ordered the dissolution pursuant to the terms specified in the agreement. Two months later, W moved for relief from judgment, alleging that she had entered into the separation agreement while under duress and that H had misrepresented his financial status. The court ruled for W, and H appealed. H contests the admissibility of the hearing testimony of Marilyn Zeidner, an assistant director of a local battered women's shelter. Zeidner never observed W prior to the dissolution, and that her testimony concerned only general aspects of battered woman syndrome, and that the admissibility of evidence of battered woman syndrome is limited to criminal proceedings

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