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.

The Court of Appeals partially affirmed and partially reversed the Trial Court's decision, ruling that Kent County Circuit Court lacked jurisdiction over the child custody matters, while Ottawa County Circuit Court erred in denying a motion to quash without considering alternative arguments related to continuing jurisdiction.