In a divorce action filed almost ten years after a Consent Judgment of Separate Maintenance was entered including an order to sell the marital home and non-modifiable alimony payments, the Court of Appeals held that the parties’ agreements in the separate maintenance action were binding on the Trial Court in entering a subsequent Judgment of Divorce, except on issues where the parties both requested modification.

When a parent challenges the validity of a release of parental rights on the ground that it was not made knowingly or voluntarily, the parent alleges a concrete injury arising from the trial court’s order and qualifies as an aggrieved party for purposes of appellate jurisdiction.

The Court of Appeals found that the parties’ unambiguous consent judgment of divorce demonstrated their intent to only modify spousal support.