Tremble v. Tremble, 288 Ga. 666

Debra Tremble (Wife) filed for divorce from Lamar Tremble (Husband) in Bulloch County in 2006.
A May 5–7, 2008 jury trial led to a Final Judgment and Decree of Total Divorce on June 18, 2009 (unsigned).
A July 17, 2009 signed Final Judgment incorporated a QDRO allocating Husband's 401(k) to Wife.
Husband attempted to file a premature motion for new trial on July 10, 2009, which was not stamped filed.
On September 14, 2009, the trial court entered a second Final Decree identical to the July 17 order but without the attached QDRO, referencing it as attached.
Wife moved to set aside the September 14 Decree; the court denied, asserting correction under OCGA § 9-11-60(g) for clerical errors.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the September 14, 2009 Decree was void for entering after the term	Wife	Husband	Yes; September 14 Decree void for being outside term.
Whether OCGA § 9-11-60(g) may correct clerical errors after term to authorize a new decree	Wife	Husband	No; clerical correction cannot validate a decree issued after term.
Whether a premature motion for new trial can conceptually justify later correction	Wife	Husband	No; premature motion cannot be used to justify a post-term correction.
Whether the August 17, 2009 QDRO was properly incorporated and attached	Wife	Husband	QDRO referenced but not attached in September order; not proper to effectuate.

Taylor v. Peachbelt Properties, Inc., 293 Ga. App. 335 (Ga. App. 2008) (rule on the term of court limits to modify or vacate)
Bank of Tupelo v. Collier, 192 Ga. 409 (Ga. 1941) (clerical errors may be corrected after term when appearing in the record)
Harrison v. Harrison, 229 Ga. 692 (Ga. 1972) (premature motions for new trial are void)
Park v. Park, 233 Ga. 36 (Ga. 1974) (no correction of a judgment for typos not present)
Andrew L. Parks, Inc. v. SunTrust Bank, 248 Ga. App. 846 (Ga. App. 2001) (clerical error correction cannot salvage post-term decree)