Richard Charles Fontaine v. Joan Thomas Guth

In this appeal, defendant-appellant Joan Thomas Guth (f.k.a. Joan Thomas Fontaine) appeals from the district court’s determination that the 1986 Qualified Domestic Relations Order (“QDRO”) governing the equitable division of marital assets between defendant-appellant and plaintiff-appellee Richard Charles Fon-taine remains in effect. Defendant-appellant requests that the Court reverse the district court’s determination that the 1990 and 1991 QDROs, which were mutual modifications of the original 1986 QDRO, are null and void.

Georgia domestic relations law makes clear that post-judgment…