Netzer v. Reynolds

This appeal involves the authority of a court to correct its own final decree, nunc pro tunc^ more than twenty-one days after its entry. More specifically, we must decide whether the court may so amend an erroneous recital in a final decree, in order to conform it to the true state of the record, where the erroneous recital appears to deprive the court of subject-matter jurisdiction.

The question arises in the context of a domestic relations dispute. Arlene Gilbert and Julian Reynolds were married in 1950. They established a marital home at 1116 Portner Road, in the City of Alexandria, in…