Christopher C. Creekmore v. Ginger A. Creekmore

── Christopher C. Creekmore v. Ginger A. Creekmore ── Court: Court of Civil Appeals of Alabama Date: April 17, 2026 Author: Bowden Category: General Rel: April 17, 2026 Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts, 300 Dexter Avenue, Montgomery, Alabama 36104-3741 ((334) 229-0650), of any typographical or other errors, in order that corrections may be made before the opinion is published in Southern Reporter. ALABAMA COURT OF CIVIL APPEALS OCTOBER TERM, 2025-2026 _________________________ CL-2025-0375 _________________________ Christopher C. Creekmore v. Ginger A. Creekmore Appeal from Elmore Circuit Court (DR-22-900138.01) BOWDEN, Judge. Christopher C. Creekmore ("the former husband") appeals from a judgment entered against him by the Elmore Circuit Court ("the circuit court") in a postdivorce contempt action between him and Ginger A. Creekmore ("the former wife"). He argues that the circuit court erred by CL-2025-0375 holding him in contempt for failing to pay the former wife alimony and by improperly modifying the alimony award. He also argues that the circuit court erred in ordering the clerk of the circuit court to execute a warranty deed vesting title in the parties' marital home in the former wife. We reverse and remand. Background and Procedural History The parties were divorced on August 25, 2022. The circuit court's final decree of divorce fully incorporated a settlement agreement between the parties. The parties' settlement agreement addressed, in pertinent part, alimony and the parties' marital home. The alimony provision of that agreement stated: "VI. ALIMONY "Section 6.1 -- Spousal Support "Husband shall pay to Wife rehabilitative alimony in the amount of One Thousand Two Hundred Dollars ($1,200.00) per month beginning on the first day of the first month following the execution of this Agreement and continuing monthly thereafter on the first day of the month until the month Husband retires from the United States Air Force. "Section 6.2 -- Retirement Accounts "A. Wife shall receive Fifty Percent (50%) of the disposable military retired pay of the Husband beginning immediately upon Husband's receipt of said retirement pay. 2 CL-2025-0375 The payment of Wife's share of the military retirement pay shall be made directly to Wife by the Defense Finance and Accounting Service (DFAS). "B. The Husband waives any and all claims to the Wife's retirement and investment accounts, benefits, and other entitlements." (Capitalization in original.) The provision of the settlement agreement that addressed the parties' marital home stated: "The parties acknowledge that they acquired real property ... and maintained said real property as the marital residence (the 'Marital Residence'). The parties acknowledge and agree that Wife shall retain sole possession with the Husband retaining sole title of the Marital Residence subject to the terms herein. "Husband shall be responsible for all monthly payments and insurance of said marital residence. Wife shall be responsible for all utilities and maintenance of said marital residence during her occupancy of the residence. "The parties further agree that beginning on the first day of the first month following the execution of this Agreement, Wife shall lease the Marital Residence from the Husband on a 'rent-to-own' basis. Wife's monthly lease