Marriage of Alexander v. Alexander, 357 P.3d 481

Rhonda and Joseph Alexander filed for divorce based on incompatibility; both agreed dissolution was appropriate.
Rhonda, terminally ill (stage-four lung cancer), asked the court to grant the divorce quickly so she could leave her share of the estate to her daughters.
On August 20, 2013 the trial judge orally pronounced the parties "divorced from the other henceforth," and filed a signed Court Minute directing mediation and requiring a journal entry within ten days; no journal entry was ever submitted.
Rhonda died on October 10, 2013, before property division was resolved and before any journal entry was filed.
Joseph moved to dismiss, arguing the death abated the action and the court lacked jurisdiction absent a filed final decree; the trial court granted the motion and the Court of Civil Appeals affirmed.
The Oklahoma Supreme Court granted certiorari and reversed, holding the dissolution was effective when pronounced and remanding for property division.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a dissolution pronounced in court is effective when pronounced despite no filed journal entry and a party's subsequent death	Appellants: Pronouncement of divorce is immediately enforceable under 12 O.S. § 696.2(E); journalization affects appealability, not effectiveness	Alexander: Death of a party before a final filed decree abates the action and deprives the court of jurisdiction to finalize the divorce	Court: Pronouncement of divorce was effective when made; absence of a filed journal entry affects appealability but not validity; dismissal for lack of jurisdiction was error — remand for property division

Corbit v. Williams, 897 P.2d 1129 (Okla. 1995) (a document titled "court minute" cannot itself constitute a judgment or appealable order)
Chastain v. Posey, 665 P.2d 1179 (Okla. 1983) (recognizes that a divorce pronouncement can effectively dissolve the marriage even if other issues remain)
Pellow v. Pellow, 714 P.2d 593 (Okla. 1985) (failure to journalize a divorce judgment does not render it void)
Whitmire v. Whitmire, 78 P.3d 556 (Okla. Civ. App. 2003) (contrary Court of Civil Appeals decision holding trial court lacked jurisdiction where spouse died before final decree; expressly overruled here)
Barnett v. Barnett, 917 P.2d 473 (Okla. 1996) (recognizes courts may reserve jurisdiction to resolve property or other issues after pronouncing a divorce)
Hibbard v. Hibbard, 247 P.2d 504 (Okla. 1952) (division of marital property and divorce are separable causes of action)