Hamilos v. Hamilos

In this case we are asked, once again, to determine whether a voluntary separation and property settlement agreement approved and incorporated but not merged in a divorce decree may be collaterally attacked. 1 Alternatively, Mrs. Hamilos argues that the decree should be modified pursuant to Maryland Rule 625 a 2 as the agreement was obtained by fraud and the decree was obtained through irregularity and mistake. For reasons discussed herein, we hold that the agreement may not be collaterally attacked as its validity was conclusively established by the decree which operates as res judicata. In…