Saxon v. Saxon
In Saxon v. Saxon, 416 So. 2d 1029, 1031 (Ala.Civ.App. 1982), the Court of Civil Appeals of Alabama ruled that a wife who was represented at the time of a consent to modification of a divorce decree and had accepted benefits from the judgment of modification was estopped from claiming the judgment was void.
The wife in that case had signed the divorce documents, but then challenged the divorce decree under Rule 60(b) of Alabama Rules of Civil Procedure.
As a product of that challenge, the parties entered into the "consent modification," which was confirmed by the court.
In a later motion to dismiss, addressed to the original decree, the wife had claimed she was not represented by counsel. Saxon, 416 So. 2d at 1030-31.