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12 Va. App. 381

404 S.E.2d 388

7 Va.LawRep. 2513

Erickson-Dickson v. Erickson-Dickson

Court of Appeals of Virginia

Decided April 30, 1991

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Court of Appeals of Virginia · decided 1991-04-30

Relies on 1 Va. App. 118 - Parra v. Parra · Morris v. Morris

Good law ✅— No negative treatment on recordhow we know

Decided 1991-04-30

How this case has been cited

Cited by 32 later decisions — most recently November 2018 · most notably 14 Va. App. 960 - O'BRIEN v. Rose (1992), 20 Va. App. 217 - Dunn v. Commonwealth (1995)

32 state decisions

160199120002010decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

View the full empirical analysis of this case →

Baker, J.,

¶1dissenting.

¶2For the reasons set forth in my dissents in Parra v. Parra, 1 Va. App. 118, 336 S.E.2d 157 (1985), and Morris v. Morris, 3 Va. App. 303, 349 S.E.2d 661 (1986), I respectfully disagree with the finding of the majority. I believe it was unnecessary for either party to object to the trial court’s erroneous attempt to reserve jurisdiction to make determinations prohibited by Code § 20-107.3 without the consent of the parties and a specific finding that the case involved complicated matter. Pursuant to Rule 1:1, I would hold that after the expiration of the twenty-one days from the entry of the final divorce decree, the trial court was without jurisdiction to enter the judgments contained in the equitable distribution decree.

¶3That portion of the divorce decree which granted the divorce is not at issue here; rather, it is the subsequent equitable distribution decree which is the basis for this appeal. Rule 1:1 and Code § 20-107.3, as amended, preclude the trial court’s actions.

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