Fahey v. Fahey
In Fahey v. Fahey, 24 Va. App. 254, 481 S.E.2d 496 (1997) (en banc), a QDRO awarded the wife "one-half of the accrued value of the Keogh Plan as of July 28, 1994."
The wife sought to amend the QDRO to include appreciation or depreciation when the interest in the plan changed.
The trial court lacked jurisdiction to modify substantively the original order to account for changed circumstances because "the manifest intent of the original order was to allot the wife one-half of the value of the . . . account on July 28, 1994." Id. at 257, 481 S.E.2d at 497.