Wood v. Wood

Clarke, Chief Justice.

This discretionary appeal presents the question of whether OCGA § 19-6-19 (the “two-year rule”) bars the husband’s petition for modification when the petition was filed within two years of the consent judgment and decree of divorce entered after the former husband’s motion for new trial. The two-year rule applies only to the period between one modification proceeding and a subsequent modification petition. The rule does not bar the first modification petition filed within two years of the original judgment and decree of divorce.1 We therefore hold that the petition in…