Lamb v. Lamb, 2011 Ohio 2970

In 1992, after a 23-year marriage, Jane and Richard Lamb were divorced and their dissolution decree incorporated a separation agreement allocating Richard’s pension.
The separation agreement contemplated Jane receiving 50% of pension benefits either as installments or in gross, via a QDRO if necessary.
The decree was initialed by a magistrate and rubber-stamped with the trial judge’s signature, raising concerns about compliance with Civil Rule 58.
In 2006 Jane moved to determine her pension portion; in 2008 a magistrate ordered Jane to draft a QDRO, which Richard objected to.
The domestic relations court adopted the magistrate’s decision; this court’s orders were appealed but initially dismissed for lack of a final order, then remanded.
In 2009 Richard moved to vacate the decree, and in 2010 the domestic relations court held the decree valid and enforceable; on appeal the court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the decree valid despite rubber-stamped signature?	Lamb argues the stamp makes the decree nonfinal/void.	Lamb contends rubber stamp defeats finality and enforceability.	Decree valid and enforceable; rubber stamp not void.
Did Richard consent to the pension division when the QDRO was entered?	Jane contends the provision was incorporated and enforceable regardless of direct agreement.	Richard never agreed to the retirement-benefits provision.	Question moot; Richard cannot challenge decree.
Are equitable defenses (laches, estoppel, waiver) barred against Jane?	Jane seeks to enforce the pension division despite elapsed time.	Equitable defenses bar relief due to delay.	Equity does not bar Jane; delay not unjustified.

Flores v. Porter, 2007-Ohio-481 (Ohio App. 2007) (rubber-stamped signature does not satisfy Civ.R. 58)
In re Mitchell, 1994-Ohio App.3d 153 (Ohio App. 1994) (rubber stamp not an acceptable signature on judgment)
State v. Simpkins, 117 Ohio St.3d 420 (Ohio 2008) (jurisdictional defects limited to subject-matter/authority)