Matter of Marriage of Pratt

Petitioner, Nadine Pratt, challenges a Court of Appeals decision which recognizes an inherent common law power of a trial court to enter a final dissolution decree nunc pro tunc. We hold that a dissolution decree is not final until signed and entered by the trial court. A nunc pro tunc decree may be entered only when necessary to correct ministerial or clerical errors or when mandated by public policy consideration. The Court of Appeals is reversed.

Nadine and Bill Pratt were married on November 11, 1978. Both had been married previously and had children from their former marriages. Four…