subject matter and the parties, a decree may nevertheless be void if “the character of the judgment was not such as the court had the power to render, or [if] the mode of procedure employed by the court was such as it might not lawfully adopt.” Anthony v. Kasey, 83 Va. 338, 340, 5 S.E. 176, 177 (1887). Watkins v. Watkins, 220 Va. 1051, 1054, 265 S.E.2d 750, 752-53 (1980) (citations omitted). Code § 20-107.3 limits the circuit court’s powers to divide property of the divorcing parties. Specifically with regard to separate property, Code § 20-107.3(C) states, “except as provided in subsection G, the court shall have no authority to order the division or transfer of separate property or marital property, or separate or marital debt, which is not jointly owned....” The statut d at 752-53 (<HOLDING>). The circuit court ruled that a resulting
recognizing the validity of a maryland judgment holding that domicile actual residency in the jurisdiction and notice of the divorce suit are sufficient enough to establish personal jurisdiction over an absent party thereby providing a basis for a collateral custody determination holding that the apparent denial of the husbands request for an order compelling the wife to deliver to him the personal property he had been awarded in their divorce judgment did not constitute a modification of the original divorce judgment holding that disposal under  9607a2 includes a partys movement and spreading of contaminated soil to uncontaminated portions of property and that congress did not limit disposal to the initial introduction of hazardous material onto property holding that the tucker acts waiver does not extend to statutory claims holding that the circuit courts statutory power in a divorce suit did not inherently extend to the disposal of the personal property of a party