Lea v. Bowers

DURHAM, Justice:

This is an appeal from a judgment modifying a divorce decree. We reverse because the trial court erred in modifying the divorce decree in the absence of factual finding of a substantial change in circumstances.

On April 29, 1974, a default Divorce Decree was entered granting a divorce to the respondent. Paragraph 7 of that decree provided as follows:

The plaintiff is hereby awarded as her sole and separate property the 1965 Chevrolet automobile, all of the household furniture, furnishings, fixtures and equipment belonging to the parties hereto and *1214the home and real property…