In the Matter of Karen Birmingham and Gregory Birmingham

Summary

The court affirmed the denial of the respondent’s requests to vacate the default divorce decree, modify the property division, and obtain retroactive modifications of child support and alimony. It held that the respondent’s lengthy failure to challenge the decree, despite receiving written notice and appearing pro se, was not excused by accident, mistake, or misfortune. It also held that the property division was final absent specified grounds undermining its validity, and that both child-support and alimony modifications could not be made retroactive before notice of the modification request.