or oppressive conduct, his act of entering into a contract with wife in which she waived spousal support and relinquished to him almost 100% of the marital estate—including the marital residence, all retirement benefits and deferred compensation—literally left her penniless with no practical means for supporting herself. These facts stand in marked contrast to those in Galloway, in which the wife had been employed outside the home throughout the couple’s 17-year marriage, and had numerous job skills, a $275,000 home she inherited, and assets of her own. 47 Va.App. at 89, 622 S.E.2d at 270. On those facts, the trial court held in Galloway “ ‘[t]here [was] no evidence ... that wife suffered from any disability or necessity.’ ” Id.; see also Derby, 8 Va.App. at 29, 378 S.E.2d at 79 (<HOLDING>). Here, the evidence established that wife had
holding that absent an actionable injury to one spouse the other spouse cannot recover for loss of consortium holding that a collective action waiver contained in a separation and release agreement was enforceable in an flsa action and noting that the enforceability of a collective waiver does not change outside the arbitration context because arbitration agreements are scrutinized under contract theories and are on equal footing with contracts citations omitted recognizing that in cases involving separation agreements unlike commercial contracts the state itself has an interest in the terms and enforceability of the agreement  because if either spouse is left in necessitous circumstances by a separation agreement that spouse  might become a public charge  holding that a spouse is not necessarily an agent of the debtor holding that the judiciary is without authority to modify alimony in a nonmerged separation agreement