LAW.coLAW.co

Deborah Elizabeth Gouch-Onassis (Formerly Foster) v. Charles Ray Foster, Sr.

2026-08-19

Summary

Holding. The court affirmed the circuit court's order dismissing Deborah's motion to reopen the divorce proceedings with prejudice, holding that res judicata barred her attempt to relitigate issues concerning property division and military retirement benefits that could have been raised in the original 2002 divorce decree or in her prior 2005 motion on the same matters.

Deborah Foster (now Gouch-Onassis) appealed a circuit court order dismissing her motion to reopen divorce proceedings from 2002. She sought to modify the property division portion of the decree, specifically requesting a portion of her ex-husband Charles's military retirement benefits and alimony. The circuit court granted Charles's motion to dismiss based on res judicata, collateral estoppel, and the statute of limitations.

The appellate court applied de novo review to the legal question of whether res judicata barred the claim. The court noted that this was Deborah's second appeal on related matters; in 2005, she had previously sought military retirement benefits and alimony, which were rejected on res judicata grounds in an earlier decision that this court had affirmed. The doctrine of res judicata prevents relitigation of claims that were raised in a prior suit or could have been raised, even when new legal theories or remedies are asserted in a subsequent action based on the same events.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Application of res judicata to bar relitigation of divorce decree issues
  • Whether prior final judgment on divorce merits precludes subsequent modification requests
  • Effect of res judicata on claims that could have been litigated in the original suit

Procedural posture

This appeal concerns a circuit court order dismissing a motion to reopen 2002 divorce proceedings, decided de novo on questions of law without factual findings.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

Cite as 2026 Ark. App. 361

ARKANSAS COURT OF APPEALS

DIVISION II

No. CV-25-434

DEBORAH ELIZABETH GOUCH- Opinion Delivered August 19, 2026

ONASSIS (FORMERLY FOSTER)

APPEAL FROM THE SEBASTIAN

APPELLANT

COUNTY CIRCUIT COURT, FORT

SMITH DISTRICT

V. [NO. 66FDR-02-51]

CHARLES RAY FOSTER, SR. HONORABLE SHANNON L. BLATT,

APPELLEE JUDGE

AFFIRMED

ROBERT J. GLADWIN, Judge

Appellant Deborah Elizabeth Foster (Gouch-Onassis) appeals from an order of the

Sebastian County Circuit Court granting the motion of appellee Charles Ray Foster, Sr., to

dismiss her request to reopen their 2002 divorce case. This is Deborah’s second appeal to this

court on related issues. See Foster v. Foster, 96 Ark. App. 109, 239 S.W.3d 1 (2006). We affirm.

I. Background Facts

The parties were divorced September 6, 2002, by a decree granting an absolute divorce,

dividing the property and debts, and granting temporary custody to appellee. No visitation or

child support was awarded at that time. As stated in the decree, the circuit court retained

jurisdiction “of this matter and the parties to make further orders in the future as may be proper

in law and equity.” Id. at 110, 239 S.W.3d at 2. In 2005, Deborah sought a portion of Charles’s

military retirement to which he became entitled after the decree was filed. She also sought alimony from Charles. On August 9, 2005, the circuit court entered an order stating that

Deborah’s motion was barred by res judicata; thus, she was not entitled to a portion of Charles’s

military retirement. Deborah appealed, and this court affirmed the circuit court’s order holding

that res judicata barred review. See Foster, supra.

On January 27, 2025, Deborah filed a motion to reopen the divorce proceedings

requesting that certain portions of the divorce decree regarding property division be modified,

including, but not limited to, her entitlement to half of Charles’s military retirement. In

response, Charles filed a motion to dismiss arguing that Deborah’s request should be denied

and motion dismissed on the basis of res judicata, collateral estoppel, and the statute of

limitations. The circuit court entered its order on May 15, 2025, dismissing the action with

prejudice. Deborah timely appealed the order of dismissal; this appeal followed.

II. Standard of Review

When the issues on appeal do not involve factual questions but rather the application of

the legal doctrine of res judicata, this court simply determines whether the appellee was entitled

to judgment as a matter of law. Daily v. Langham, 2017 Ark. App. 310, 522 S.W.3d 177. When

a complaint is dismissed on a question of law, this court conducts a de novo review; the circuit

court’s ruling is given no deference on appeal. Duggar v. City of Springdale, 2020 Ark. App. 220,

599 S.W.3d 672.

III. Discussion

Here, after the court held a hearing on Charles’s request to dismiss on the basis of res

judicata, the circuit court granted his request and dismissed the case with prejudice. No factual

findings were made.

2

Res judicata means that “a thing or matter has been definitely and finally settled and

determined on its merits by the decision of a court of competent jurisdiction.” Baptist Health v.

Murphy, 2010 Ark. 358, at 7, 373 S.W.3d 267, 278. The claim-preclusion aspect of res judicata

bars relitigation of a subsequent suit when (1) the first suit resulted in a final judgment on the

merits; (2) the first suit was based on proper jurisdiction; (3) the first suit was fully contested in

good faith; (4) both suits involve the same claim or cause of action; and (5) both suits involve

the same parties or their privies. Id. Res judicata bars relitigation of not only claims that were

actually litigated in the first suit but also those that could have been litigated. Id. When a case is

based on the same events as the subject matter of a previous lawsuit, res judicata will apply even

if the subsequent lawsuit raises new legal issues and seeks additional remedies. Id.

On appeal, Deborah raises a litany of issues regarding her entitlement to years’ worth of

alimony and Charles’s military retirement benefits. As discussed above, this court has already

held that the divorce decree herein was a final judgment and that res judicata prevents the

relitigation of any issues that Deborah raised in 2002 or that she could have raised. See Foster,

supra. Therefore, we decline to further address this matter. Accordingly, we affirm the circuit

court’s order of dismissal with prejudice.

Affirmed.

TUCKER and BARRETT, JJ., agree.

Deborah Elizabeth Gouch-Onassis, pro se appellant.

Gean, Gean & Gean, by: David Charles Gean, for appellee.

3