Dean v. Dean

NAHMIAS, Justice.

More than 30 years ago this Court adopted the straightforward rule that

parties to an alimony agreement may obtain modification unless the agreement expressly waives the right of modification by referring specifically to that right; the right to modification will be waived by agreement of the parties only in very clear waiver language which refers to the right of modification.

Varn v. Varn, 242 Ga. 309, 311 (248 SE2d 667) (1978). The trial court in this case read a divorce settlement agreement to forbid changes to child support payments below a floor amount, even though the…