In an in rem or quasi-in-rem action, a judgment is limited to the property that supports jurisdiction and does not impose a personal liability on the property owner. See Brown v. Rock, 184 Ga. App. 699, 700(2)( 362 S.E.2d 480)(1987). O.C.G.A. § 23-3-65 (b), which applies to proceedings brought to remove a cloud upon title to land, provides:

See Williams v. Fuller, 244 Ga. 846, 850 (5)( 262 S.E.2d 135) (1979); Harbin Enterprises v. Sysco Corp., 195 Ga. App. 694, 695 (1) ( 394 S.E.2d 618) (1990). See Brown v. Rock, 184 Ga. App. 699, 701 (2) ( 362 S.E.2d 480) (1987); Hubbert v. Williams, 175 Ga. App. 393, 396 (3) ( 333 S.E.2d 425) (1985). 3. Based on the foregoing, we need not consider Davis-Redding's remaining arguments.

Thus, construing the petitions so as to do substantial justice, OCGA § 9-11-8 (f), it is clear that each stated a viable claim for the condemnation of currency used in, or intended for use in, unlawful gambling activity. Brown v. Rock, 184 Ga. App. 699 ( 362 S.E.2d 480); OCGA § 16-12-32. See generally State of Ga. v. Walls, 202 Ga. App. 899 ( 415 S.E.2d 921). Besides, the petitions were amended by the gambling evidence introduced at trial.

None of these other appellate courts, however, has expressly addressed the question of whether a civil court can enforce an agreement to submit a dispute to a Beth Din without running afoul of the First Amendment. While case law in three of the states suggests that actions are to be dismissed whenever it appears that subject matter jurisdiction is lacking, even if the issue has not been raised by any of the parties, see People v. J.M., 854 P.2d 1346, 1350 (Colo.Ct.App. 1992); Brown v. Rock, 184 Ga.App. 699, 362 S.E.2d 480, 481 (1987); Duffy v. Conaway, 295 Md. 242, 455 A.2d 955, 961 n. 8 (1983), and while in the fourth state a lack of subject matter jurisdiction has been deemed a basic defect that can be raised at any time, see Barnick v. Longs Drug Stores, Inc., 203 Cal.App.3d 377, 250 Cal.Rptr. 10, 11-12 (1988), we are reluctant, in the absence of any affirmative discussion of the First Amendment issue, to draw any conclusions concerning our own subject matter jurisdiction from the fact that appellate courts in California, Georgia, Colorado, and Maryland have reached the merits of actions to enforce agreements to submit disputes to Beth Dins. The case before us presents an even stronger claim for the application of "neutral principles of law" than that presented in Avitzur.

Id. at 1007. See also Brown v. Rock (1987), 184 Ga. App. 699, 362 S.E.2d 480 (in an action seeking domestication of a judgment in order to eventually garnish against property owned in the state, personal jurisdiction is not required). Clearly, the relief sought by Christina against John's military benefits rendered this action an in rem or quasi in rem proceeding. John argues that a support action is an in personam proceeding and that Christina's petition to register and enforce a foreign support order was in personam in nature, citing Jennings v. Jennings (1988), Ind. App., 531 N.E.2d 1204.