In the Matter of the Marriage of Joann Williams, Appellee, and Alfonza Williams, Appellant.

Summary

The court held that the federal statute governing division of military retirement benefits limits a state court's exercise of personal jurisdiction over the servicemember, not the court's subject-matter jurisdiction. Because Alfonza participated in the divorce proceeding without objecting after the retirement benefits were placed in issue, he impliedly consented to personal jurisdiction and waived the objection. The court also upheld the award of attorney fees because the proceeding substantively concerned division of marital property, while denying Joann's separate request for appellate attorney fees for failure to provide the required affidavit.