Jill Eden built a home on property owned by relatives and later settled a quiet-title dispute by an agreement requiring them to convey her a life estate and access rights, maintain insurance, pay taxes, and make monthly payments. The trial court incorporated the settlement into an enforcement order. After the relatives recorded a fee-simple deed, the court denied Jill’s second contempt motion but found that the deed satisfied the life-estate obligation and relieved the relatives of the monthly payments. The Georgia Court of Appeals affirmed the denial of contempt but vacated the finding that the relatives no longer owed the payments. The settlement required changes to be in writing, and the record did not show that Jill agreed to exchange the monthly payments for a different deed. The trial court therefore lacked authority to modify the settlement by treating the fee-simple deed as a substitute for the agreed life estate and payment obligations. The case was affirmed in part and vacated in part.