In Re Marriage of Brown

In In Re Marriage of Brown, 225 Ill. App. 3d 733, 587 N.E.2d 648, 167 Ill. Dec. 379 (Ill. App. 3d 1992), the parties obtained a divorce in Germany while the husband-defendant was stationed there on active military duty. Brown, 587 N.E.2d at 650. Prior to the entry of divorce, the parties executed a separation agreement giving the wife-plaintiff a share of the defendant's military pension. Id. When plaintiff attempted to register the foreign judgment, the Illinois Court affirmed the dismissal of the action on the grounds that subject matter jurisdiction was lacking. Brown, 587 N.E.2d at 653. In Brown, the German divorce decree incorporated the parties' separation agreement, thereby making it part of the foreign judgment. Brown, 587 N.E.2d at 650-51.