Billionaire entertainment mogul David Geffen, 83, reached an uncontested settlement in his divorce from model Donovan Michaels, 33, after a 23-month marriage entered without a prenuptial agreement, according to The Hollywood Reporter. For California residents, the case shows how marriages under 10 years limit spousal support duration under Cal. Fam. Code § 4336 — even when one spouse is worth $9.3 billion.
Key Facts
| Detail | Summary |
|---|---|
| What happened | David Geffen and Donovan Michaels reached an uncontested divorce settlement; final terms sealed |
| When | Settlement reached 2026; marriage lasted approximately 23 months |
| Where | California (primary); parties connected to New York and California |
| Who's affected | Geffen ($9.3B net worth), 83, and Michaels, 33 — no children, no prenuptial agreement |
| Key statute/rule | Cal. Fam. Code §§ 4336 and 4320 |
| Impact | Illustrates short-marriage (under 10 years) spousal support limits and asset-disclosure duties |
Why this matters legally
A marriage of under 10 years does not automatically entitle either spouse to lifetime support in California, regardless of the other spouse's wealth. Under Cal. Fam. Code § 4336, courts generally retain jurisdiction over spousal support indefinitely only for marriages of "long duration" — defined as 10 years or more. Geffen's 23-month marriage falls far short of that threshold.
For marriages under 10 years, California courts typically limit support to roughly half the length of the marriage. A 23-month marriage would generally suggest support lasting around 11 to 12 months — which aligns closely with the 12-month, $50,000-per-month offer The Hollywood Reporter reported Geffen previously made. That $600,000 total offer, rejected during litigation, tracks the standard formula many California judges apply, though the final sealed terms are undisclosed.
The absence of a prenuptial agreement is the pivotal legal fact. Without one, California's community property and support framework governs by default. A prenuptial agreement could have waived or capped spousal support entirely, subject to the procedural safeguards of California's Uniform Premarital Agreement Act.
How California law handles this
California calculates long-term spousal support using the 14 factors listed in Cal. Fam. Code § 4320, not a simple formula. Those factors include the marital standard of living, each spouse's earning capacity, the supported party's marketable skills, the duration of the marriage, and the paying spouse's ability to pay. A judge weighs all 14 before setting an amount.
Marital duration directly shapes the support timeline. Under Cal. Fam. Code § 4336, a marriage of 10 years or longer is presumptively "long duration," meaning the court keeps authority to order support without a fixed end date. A 23-month marriage receives no such presumption, and courts routinely set a defined termination date. This is why short marriages — even to billionaires — rarely produce open-ended support.
Asset disclosure is mandatory and enforceable. Cal. Fam. Code § 2104 requires both spouses to serve a preliminary declaration of disclosure listing all assets and debts, regardless of characterization. Michaels reportedly accused Geffen of concealing assets during the proceedings. California takes such allegations seriously: under Cal. Fam. Code § 1101, a spouse who deliberately hides community property can be ordered to pay the other spouse 100% of the undisclosed asset's value, plus attorney's fees. This penalty exists specifically to deter the kind of concealment Michaels alleged.
Community property is divided equally under Cal. Fam. Code § 760, but only property acquired during the marriage qualifies. Most of Geffen's $9.3 billion fortune predates the 23-month marriage, making it his separate property and generally not subject to division. This is a critical distinction: wealth accumulated before the wedding stays with the spouse who earned it, absent commingling or transmutation.
Practical takeaways
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Sign a prenuptial agreement before a high-asset marriage. A valid prenup can waive or cap spousal support and confirm the separate-property status of pre-marital wealth. California requires at least seven days between presenting the agreement and signing, plus independent counsel for enforceability.
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Understand the 10-year rule before assuming lifetime support. Under Cal. Fam. Code § 4336, only marriages of 10 years or more are presumed "long duration." If your marriage is shorter, expect support limited to roughly half the marriage length. Map your situation with a personalized divorce roadmap.
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Complete your financial disclosures honestly and completely. Cal. Fam. Code § 2104 mandates full disclosure of every asset and debt. Concealment can cost you 100% of the hidden asset under Cal. Fam. Code § 1101. Learn how the broader divorce process protects both spouses.
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Distinguish separate property from community property early. Wealth acquired before marriage is generally separate under Cal. Fam. Code § 760 and not divisible. Keep pre-marital assets in separate accounts to avoid commingling.
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Consider an uncontested divorce when terms can be negotiated. Geffen and Michaels ultimately settled rather than litigate to trial. Settlement keeps terms private, reduces cost, and speeds resolution. Estimate your own costs with our divorce cost estimator.
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Retain experienced counsel for high-asset or contested support disputes. When allegations of hidden assets arise, a family law attorney can compel discovery, subpoena financial records, and pursue the penalties § 1101 provides. You can find a divorce attorney serving your county.
Whether you are navigating a short marriage, a high-asset estate, or an asset-disclosure dispute, understanding how California applies §§ 4320 and 4336 helps you set realistic expectations before you file. If you are facing a divorce involving significant assets or questions about spousal support duration, speaking with a qualified California family law attorney can clarify where you stand.
This article discusses recent news and provides general legal commentary. It does not constitute legal advice. Every case is unique. Consult a qualified family law attorney for advice specific to your situation.