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THE MECHANICS OF DIVIDING RETIREMENT BENEFITS: RECENT CASE LAW ON PREPARATION OF QUALIFIED DOMESTIC RELATIONS ORDERS
© 1998 National Legal Research Group, Inc.
Background: The Need for QDROs
The great majority of all private future benefit plans are regulated by the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. (1985 & Supp. 1993). Among the many provisions of ERISA is an antiassignment clause which prevents pension owners from transferring their pension rights to another person. 26 U.S.C. 401(a)(13)(B) (Supp. 1993); 29 U.S.C. 1056(d)(3)(A) (Supp. 1993).
Before 1984, there was considerable discussion as to whether the antiassignment clause applied in divorce proceedings. Most of the reported state court decisions found no federal preemption, but a number of commentators were afraid that the Supreme Court would use the antiassignment clause to prevent state courts from dividing any retirement plan regulated by ERISA. See generally Ryan v. Ryan, 626 S.W.2d 103 (Tex. App. 1981) (sample case finding no preemption); Raggio & Raggio, McCarty v. McCarty: The Moving Target of Federal Preemption, Threatening All Non-Employee Spouses, 13 St. Mary's L.J. 505 (1982) (expressing the fear that federal preemption might apply to all pensions regulated by ERISA); Lawrence J. Golden, Equitable Distribution of Property 6.07 (1983). Such a holding would be practically devastating, because its effect would be to prevent the division of retirement benefits, which frequently constitute the most substantial asset of the parties.
Congress responded to this threat in 1984 by amending the antiassignment clause. Under the amendment, the antiassignment clause does apply in divorce proceedings. 26 U.S.C. 401(a)(13)(B) (Supp. 1993); 29 U.S.C. 1056(d)(3)(A) (1985 & Supp. 1993). Federal preemption is therefore the general rule. The antiassignment clause does not apply, however, if a state court order dividing plan benefits constitutes a qualified domestic relations order (QDRO). 26 U.S.C. 401(a)(13)(B) (Supp. 1993); 29 U.S.C. 1056(d)(3)(A), 1144(b)(7) (1985 & Supp. 1993). The requirements for a QDRO are almost all matters of form, and it is possible to draft a qualifying order in essentially every divorce case. In effect, therefore, the 1984 amendment removed the threat that federal law would prevent the division of retirement benefits across the board.
For specific case law holding that ERISA-regulated benefits may be divided by a properly drafted QDRO, see, e.g., In re Williams, 163 Cal. App. 3d 753, 209 Cal. Rptr. 827 (1985); In re Baker, 204 Cal. App. 3d 206, 251 Cal. Rptr. 126 (1988); Roth v. Roth, 201 Mich. App. 563, 506 N.W.2d 900 (1993); Parker v. Parker, 641 So. 2d 1133 (Miss. 1994); Mayefsky v. Mayefsky, 184 A.D.2d 954, 585 N.Y.S.2d 131 (1992); Hoyt v. Hoyt, 53 Ohio St. 2d 177, 559 N.E.2d 1292 (1990); and Arena v. Arena, 822 S.W.2d 645 (Tex. App. 1991).
The QDRO Requirements
In order for the 1984 amendment to apply, however, the order which actually divides retirement benefits must meet the technical QDRO requirements. While it is possible to meet these requirements in a divorce decree, the easier practice is to enter the QDRO as a separate order at a later date. The technical drafting requirements of a QDRO have materially increased the complexity of state court orders dividing retirement benefits. In addition, the fact that pension division now requires two orders rather than one has added an additional layer of complexity to the state law of divorce procedure.
The technical definition of a QDRO is set forth at 26 U.S.C. 414(p)(1) (Supp. 1993); 29 U.S.C. 1056(d)(3)(B) (Supp. 1993). To begin with, in order to constitute a qualified domestic relations order, the order must first constitute a domestic relations order. A "domestic relations order" is any order (including approval of a property settlement agreement) which grants child support, alimony, or property rights to the pension owner's spouse under state domestic relations law. 26 U.S.C. 414(p)(1)(B) (Supp. 1993); 29 U.S.C. 1056(d)(3)(B)(ii) (Supp. 1993).
A domestic relations order constitutes a qualified domestic relations order if the following requirements are met:
1. The order must be one which "creates or recognizes the existence of an alternate payee's right to . . . receive all or a portion of the benefits" payable to the owner. 26 U.S.C. 414(p)(1)(A) (Supp. 1993); 29 U.S.C. 1056(d)(3)(B)(i) (Supp. 1993).
2. The order must specify the name and last known mailing address of each participant and each alternate payee; the amount or percentage to be received by each alternate payee (or the manner in which the amount or percentage should be determined); the number of payments or periods for which the order is effective; and the precise retirement plan or plans to which the order applies. 26 U.S.C. 414(p)(2) (Supp. 1993); 29 U.S.C. 1056(d)(3)(C) (Supp. 1993).
3. The order may not require the plan to provide to an alternate payee any type, form, or amount of benefit not normally available to the owning spouse. It also may not order the plan administrator to provide to one alternate payee any benefit already being paid to another alternate payee under another QDRO. 26 U.S.C. 414(p)(3) (Supp. 1993); 29 U.S.C. 1056(d)(3)(D) (Supp. 1993).
4. The order cannot require that payments to the nonowning spouse begin before the earliest date of retirement under the plan. ERISA states this rule in the negative, stating that an order shall not be deemed unqualified for providing the nonowning spouse a benefit not available to the owning spouse (see paragraph 3 above) merely because it orders that benefits become payable on the earliest retirement date, even if the owning spouse has not yet actually retired. 26 U.S.C. 414(p)(3); 29 U.S.C. 1056(d)(3)(E)(i) (Supp. 1996). The earliest retirement date is the earliest date after age 50 as of which the owning spouse either receives benefits or could begin receiving benefits if he or she left employment. 26 U.S.C. 414(p)(3)(ii); 29 U.S.C. 1056(d)(3)(E)(ii) (Supp. 1996). The order is expressly permitted to award the nonowning spouse a share of the benefits which the owning spouse would receive if he or she had retired on the date payment is to begin. Such an award cannot, however, include the present value of any early retirement subsidy. 26 U.S.C. 414(p)(3)(i)(II); 29 U.S.C. 1056(d)(3)(E)(i)(II) (Supp. 1996). Where an employee was entitled to retire when his age and years of service combined reached 75, one court held that the early retirement benefit permitted by this rule is a subsidy. In re Oddino, 16 Cal. 4th 67, 939 P.2d 1266, 65 Cal. Rptr. 2d 566 (1997).
The degree to which the law requires strict compliance with these requirements is a difficult question. The requirement that the specific retirement plan be identified is not generally construed to require the exact technical name of the plan. Instead, any language which is reasonably sufficient to identify the plan in actual fact is sufficient. See Ross v. Ross, 308 N.J. Super. 132, 705 A.2d 784 (App. Div. 1998) (order which covered all retirement benefits received from a certain company was sufficient to cover all plans in that company's name, although not various other plans in other companies' names which were derived from that company's plans); Tolstad v. Tolstad, 527 N.W.2d 668 (N.D. 1995) (general reference to employer's life insurance plan was sufficient where employer had only one such plan).
Case law is split on the address requirements. Where the order did not include the required address information, but the plan administrator actually had that information in its personnel records, one court held that there was substantial compliance with the statute. Tolstad v. Tolstad, 527 N.W.2d 668 (N.D. 1995). Conversely, other courts have demanded strict compliance with these requirements. See Hawkins v. Commissioner, 86 F.3d 982 (10th Cir. 1996); Ross v. Ross, 308 N.J. Super. 132, 705 A.2d 784 (App. Div. 1998).
The requirement that the order not divide any benefit which is not actually available under the plan is the core of the QDRO definition, and on this point the courts have quite properly given the order no flexibility. In the author's experience, way too many state courts and attorneys attempt to divide retirement benefits without a full understanding of exactly what is being divided. The resulting orders are often unfair to one spouse or the other, and they are always a nightmare for the plan administrator. By requiring that the court and the parties understand the pension plan and speak the language of the plan administrator, the QDRO requirements not only make pension plans easier to administer, but also increase the fairness of state court pension division orders. It is absolutely fundamental that the drafter of a QDRO understand the terms of the specific plan at issue, and divide between the parties only the benefits which the employer actually offers.
QDRO Procedure: Federal Law
The procedure for determining whether an order meets the above requirements is also set forth by federal law. The procedure ordinarily begins when a state court issues an order which purports to be a QDRO. That order is then submitted to the plan administrator, who reviews the order for compliance with the federal requirements. Federal law requires each pension plan to establish reasonable procedures for making this review, and requires that the administrator notify both spouses of its determination. 26 U.S.C. 414(p)(6) (Supp. 1993); 29 U.S.C. 1056(d)(3)(G) (Supp. 1993). While the administrator is considering whether the order is a QDRO, it must keep the nonowning spouse's benefits segregated; and if the order is found to be a QDRO within 18 months of its submission to the administrator, the nonowning spouse is entitled to the segregated benefits. 26 U.S.C. 414(p)(7) (Supp. 1993); 29 U.S.C. 1056(d)(3)(H) (Supp. 1993).
In Winter v. Boskin, 181 A.D.2d 1000, 582 N.Y.S.2d 573 (1992), the court erroneously held that this section requires that the QDRO itself order segregation. On the contrary, a plain reading of the statutory language shows that the plan administrator must segregate funds regardless of what the order requires. The segregation provisions are meant only to protect the nonowning spouse's rights while the qualified status of the order is being determined. Future cases should not construe those provisions as additional requirements which the order must meet in order to constitute a QDRO.
If the plan administrator determines that the order is a valid QDRO, the point is prima facie established, and payments can begin as soon as they are due under the order. In re Bruns, 535 N.W.2d 157 (Iowa Ct. App. 1995) (approval of plan administrator is a necessary element of a QDRO). If the plan administrator determines that the order is not a QDRO, the order is prima facienot enforceable, and immediate compliance is not required. Indeed, since there is no established exception to the antiassignment provision, immediate compliance would violate ERISA.
If either spouse disagrees with the plan administrator's determination of whether an order is a QDRO, the administrator's decision can be reviewed by a judge. The cases hold that federal and state courts have concurrent jurisdiction to make this determination. See Board of Trustees of Laborers' Pension Trust Fund v. Levingston, 816 F. Supp. 1496 (N.D. Cal. 1993); In re Oddino, 16 Cal. 4th 67, 939 P.2d 1266, 65 Cal. Rptr. 2d 566 (1997); In re Levingston, 12 Cal. App. 4th 1303, 16 Cal. Rptr. 2d 100 (1993). The Department of Labor initially took the position that jurisdiction was concurrent, see Advisory Opinion 92-17A of the U.S. Department of Labor, 18 Fam. L. Rep. (BNA) 1599 (1992) (plan administrator may accept as binding a state court order holding that a particular person is in fact the pension owner's spouse), but it then argued in the Oddino case that jurisdiction was proper only in the federal courts. There is no reason to add to the caseload of the federal courts an entirely new category of domestic relations disputes, and no reason to suspect that state courts will not fairly enforce the definition of a QDRO. The Department's initial position was therefore the correct one.
Pre-1984 Orders. The plan administrator must treat a pre-1984 order as a QDRO if it was actually complying with it before the Act. Further, the plan administrator has discretion to treat any other pre-Act order as a QDRO. Pub. L. No. 98-397, 303(d), 98 Stat. 1426, 1453 (1984). This section was not codified, but it is reprinted at 29 U.S.C. 1001 note (1985). For case law applying the statute, see Arena v. Arena, 822 S.W.2d 645 (Tex. App. 1991).
Effect of a QDRO
The main effect of a QDRO, of course, is that it permits the plan administrator to send benefits directly to the nonowning spouse without violating the antiassignment provision of ERISA.
A QDRO also has an important effect upon the parties' tax liability. When payments are made pursuant to a QDRO, they are treated as income to the recipient and not as income to the owning spouse. By contrast, if the court merely orders payments from the owning spouse to the nonowning spouse, the benefits are income only to the owning spouse, who must therefore pay all of the taxes on both spouses' share of the pension. See Cameron v. Cameron, 570 So. 2d 1087 (Fla. Dist. Ct. App. 1990).
After entry of a QDRO, the nonowning spouse is equitably the owner of his or her share of the benefits. The most important application of this doctrine is in bankruptcy, where the courts hold that the plan administrator's obligation to make payments under a QDRO is not a debt of the petitioner, and the non-owner's pension benefits are not part of the petitioner's estate, so that the obligation cannot be discharged. See, e.g., In re McCafferty, 96 F.3d 192 (6th Cir. 1996); Bush v. Taylor, 912 F.2d 989 (8th Cir. 1990); In re Gendreau, 122 F.3d 815 (9th Cir. 1997) (even if QDRO was not issued until after bankruptcy petition was filed); In re Granados, 214 B.R. 241 (Bankr. E.D. Cal. 1997); In re Califf, 195 B.R. 499 (Bankr. N.D. Ala. 1996); In re Potter, 159 B.R. 672 (Bankr. N.D.N.Y. 1993); In re Bennett, 175 B.R. 181 (Bankr. E.D. Pa. 1994); In re DeBolt, 177 B.R. 31 (Bankr. W.D. Pa. 1994); Gallant v. Gallant, 882 P.2d 1252 (Alaska 1994); Clark v. Clark, 219 A.D.2d 787, 631 N.Y.S.2d 467 (1995); Dewey v. Dewey, 188 Wis. 2d 271, 525 N.W.2d 85 (1994).
Courts have reached analogous results in other areas. See L.M. v. Division of Medical Assistance & Health Services, 140 N.J. 480, 659 A.2d 450 (1995) (after entry of QDRO, husband does not own wife's share of benefits for purposes of Medicaid eligibility).
QDRO Procedure: State Law
Most state divorce procedure is based upon the assumption that the court will enter one single order which resolves all outstanding property division issues. When pension issues are involved, however, most courts will enter two orders: one which divides the property, and one which specifically meets the QDRO requirements. The presence of this second order has created a variety of state law procedural issues. These issues can be quite challenging to resolve, and they account for a majority of the recent QDRO-related litigation.
To begin with, what if the original order fails to meet the QDRO requirements? It is a fundamental axiom of state property division law that property division judgments cannot generally be modified after they have become final. In almost every instance, by the time the plan administrator determines whether an order constitutes a QDRO, the order has become final. Does the rule against modification then prohibit the court from making the changes needed to meet the QDRO requirements?
Preliminary Review. The first line of defense against this problem is to avoid its occurrence. Because it is difficult to obtain modification of an order which has already been entered, most plan administrators are willing to review prospective orders. By using this preliminary review procedure, attorneys can get the plan administrator to approve the terms of a proposed QDRO before the court enters it as a judgment. Since a proposed order can be freely modified, this procedure gives the parties much greater flexibility in drafting the order.
Procedural Modification. Preliminary review is not, however, a complete answer. Some employers do not conduct such reviews, and some parties do not take advantage of their availability. Also, if there is a bona fide dispute over whether an order meets the requirements, the order must be presented and rejected by the administrator before a court can consider the question. If the plan administrator prevails in such an action, or if preliminary review is not used for other reasons, is it too late to modify the order?
Case law on this subject is still developing, but the general answer appears to be no. The developing trend is to view a QDRO not as a substantive order on the merits, but rather as a procedural order which enforces underlying substantive rights. See generally Seal v. Raw, 954 S.W.2d 681 (Mo. Ct. App. 1997); Davidson v. Davidson, 916 S.W.2d 918 (Tenn. Ct. App. 1995). While the court cannot generally modify a substantive property division order, it is permitted to add new or different procedural terms for the purposes of enforcement. Turner, supra, 9.06. Because a QDRO is fundamentally an enforcement device, most courts permit unlimited modification to make that enforcement device effective, so long as the parties' underlying substantive rights are left unchanged.
In addition, an increasing number of states are enacting statutes which permit final judgments to be reopened for the limited purpose of meeting the technical requirements of a QDRO. See Mo. Rev. Stat. 452.330(5) (Supp. 1993); Va. Code Ann. 20-107.3(K)(4) (Michie Supp. 1993). These statutes are commended to legislatures in other states. The definition of a QDRO is complex, and it is often hard to tell from the face of an order whether the plan administrator will accept it as a QDRO. A spouse who seeks a division of pension benefits should not be forced to bear the risk that despite the best efforts of the trial judge and both attorneys one of the technical requirements of a QDRO might not be met. As long as the amount distributed to each spouse remains unchanged, the trial court should be free to amend an order so that it constitutes a QDRO under federal law.
In states which lack specific statutes, the prudent QDRO drafter can provide for a similar result by expressly including in the order a provision reserving jurisdiction to make future nonsubstantive modifications. Such a reservation is permitted and enforceable. See, e.g., Munson v. Munson, ___ A.D.2d ___, 663 N.Y.S.2d 441 (1997); Schrader v. Schrader, 108 Ohio App. 3d 25, 669 N.E.2d 878 (1995).
The all-time, worst-case scenario involving procedural modification is a potential future change in the definition of a QDRO as set forth in federal law. Congress has thankfully refrained from micromanaging the pension division provisions of ERISA in the same way it has micromanaged the statutory provisions governing the division of military retirement benefits upon divorce. See 10 U.S.C. 1408 (1996 & Supp. 1998). Still, the history of federal legislation on the division of retirement benefits suggests that such laws are a complex political balancing act between the rights of nonowning spouses and the convenience of plan administrators, and a cynic could observe without fear of blatant error that Congress has often shown more concern for the plan administrators. It is therefore far from impossible that Congress might at some point add additional requirements to those listed above. If the effect of such a modification were to disqualify prior QDROs, there would be great disruption in state domestic relations law. This potential chaos can be largely avoided by the enactment of statutes or by the inclusion of specific provisions reserving jurisdiction to make nonsubstantive modifications in prior pension division orders.
Substantive Modification. It is worth repeating that, under either the statutory or case law approach to modification, the order can be changed only for purposes of enforcement that is, to ensure that the nonowning spouse receives his or her share of the benefits at issue. If the court goes further and actually changes the amount of the non-owning spouse's share, the modification violates the rule against modification of final property division orders. SeeCastrigno v. Castrigno, 219 A.D.2d 694, 631 N.Y.S.2d 759 (1995); Schrader v. Schrader, 108 Ohio App. 3d 25, 669 N.E.2d 878 (1995) (substantive modification was not only erroneous, but legally void, so that the issue could be raised for the first time on appeal); Stockton v. Stockton, 698 A.2d 1334 (Pa. Super. Ct. 1997); Caudle v. Caudle, 18 Va. App. 795, 447 S.E.2d 247 (1994); Newsome v. Newsome, 18 Va. App. 22, 441 S.E.2d 346 (1994). Along similar lines, a statute permitting modification of a QDRO obviously cannot be used to replace a QDRO with an order which does not constitute a QDRO. Offield v. Offield, 955 S.W.2d 247 (Mo. Ct. App. 1997).
The line between procedural and substantive modification is subtle, and it is easy for the drafter to stumble upon it. In Fahey v. Fahey, 24 Va. App. 254, 481 S.E.2d 496 (1997), a QDRO gave the nonowning spouse half of the value of the pension as of a specified date. Between that date and the date the plan administrator recognized and qualified the order, the plan increased in value substantially. The court reversed a lower court decision giving the wife half of the increase, finding it to be an improper substantive modification. By contrast, in Brown v. Brown, 235 A.D.2d 383, 652 N.Y.S.2d 75 (1997), the court expressly permitted amendment of a QDRO to allocate equally postdivorce gains and losses. Since the spouse to whom an asset is awarded is generally entitled to all appreciation, dividends, and the like which accumulate between the entry of the final order and the actual date of distribution, Brown is the better-reasoned decision.
While QDRO modification statutes and case law create an exception to the rule that property divisions cannot be modified, they do not create an exception to the basic principles of res judicata. For instance, where a spouse attempts to obtain modification and fails, the spouse cannot rely on the modification statute as authority for bringing the same suit again. Walker v. Walker, 954 S.W.2d 425 (Mo. Ct. App. 1997). The purpose of these statutes is to permit the court to respond to changed circumstances, such as rejection of the QDRO by the plan administrator or a change in the definition of a QDRO under federal law. Where there is no such change, modification should not be permitted.
Of course, an order can be modified for any reason, whether procedural or substantive, if the court finds a sufficient basis on the facts to modify a final judgment. Such modification has been permitted where the underlying QDRO was ambiguous, see Weller v. Weller, 115 Ohio App. 3d 173, 684 N.E.2d 1284 (1996) (trial court did not improperly modify QDRO by ruling that it divided only permanent and not temporary retirement benefits), and where the petitioner proved the necessary grounds to reopen a judgment. SeeCarlson v. Carlson, 108 Nev. 358, 832 P.2d 380 (1992) (finding sufficient fraud to reopen the judgment, and ordering the trial court on remand to restate its order as a QDRO).
Substantive Variance. In the great majority of all cases, the QDRO will track the terms of the final decree. In some cases, however, the opposite will be true. Assume, for instance, that a final decree awards the wife 40% of the husband's pension. The court then enters a QDRO awarding the wife 50% of that pension. The QDRO is of course in error and, if it is appealed, it will be reversed. But what if the QDRO is not appealed, and becomes final? Is the QDRO a final order, which must be enforced as entered? Or is it a mere enforcement device, which cannot by its nature change the substantive result of the original order?
This question shows signs of developing into an important issue which will arise with some frequency. In Davidson v. Davidson, 916 S.W.2d 918 (Tenn. Ct. App. 1995), the court began with the proposition that the QDRO and the final judgment should be construed as consistent with one another if such a construction is possible. Where reconciliation is not possible, however, the court indicated that the final decree would control, because the QDRO is only an enforcement device which should not be read to establish substantive rights. On the facts, the court found the two orders to be reconcilable, and it thus did not need to choose between them. To the extent that the reconciled orders differed from the intention of the husband, the court refused to reopen the QDRO for mistake, finding that the husband's failure to read the order before it became final constituted inexcusable neglect.
In Halbert v. Halbert, 220 Ga. App. 615, 469 S.E.2d 534 (1996), the decree provided that the wife's alimony would stop when she began receiving her share of the husband's pension. The disputed question was the time at which the wife's pension benefits commenced. The majority, relying only upon the QDRO, held that the benefits began on the earliest possible date of normal retirement. The dissent, relying upon the underlying agreement as well as on the QDRO, argued that the wife had the right to elect whether her pension benefits would start (and her alimony therefore stop) at any point between the earliest possible retirement date and the actual retirement date. Because the majority applied the parol evidence rule to the QDRO alone, it appeared to hold that the QDRO controlled all prior documents. The dissent, by contrast, followed Davidson at least to the extent of holding that the documents should be read together.
Miscellaneous Procedural Issues
When an ERISA-regulated pension is divided via a QDRO, the order is binding on the pension plan, even though it is not a party to the case. In re Baker, 204 Cal. App. 3d 206, 251 Cal. Rptr. 126 (1988). Indeed, Illinois has held that a pension plan may not be made a party to a dissolution action against its will. In re Degener, 119 Ill. App. 3d 1079, 458 N.E.2d 46 (1983).
Because property division rights cannot be granted under the law of most states until the parties are divorced, the general rule is that a QDRO cannot be issued before the divorce. See Turnage v. Turnage, 653 So. 2d 485 (Fla. Dist. Ct. App. 1995) (error to grant QDRO only 16 days after filing of divorce complaint, before husband even had time to file an answer).
The court can issue a QDRO after the owning spouse has filed a petition in bankruptcy, as the QDRO merely restates the pension division portion of the divorce decree in enforceable form. Lowenschuss v. Lowenschuss, 453 Pa. Super. 340, 683 A.2d 1214 (1996).
The court cannot issue a QDRO after the death of the owning spouse. See In re Norfleet, 243 Ill. App. 3d 925, 612 N.E.2d 939 (1993); Ross v. Ross, 308 N.J. Super. 132, 705 A.2d 784 (App. Div. 1998).
Conclusion
The QDRO provisions of ERISA have added a considerable layer of complexity to the process of dividing retirement benefits. Somewhat surprisingly, the more difficult issues in the recent past have been not issues of federal law, but rather issues of state law litigated in state court. In particular, most state courts prefer to enter two final orders, a divorce decree and a QDRO, and the potential for conflict between the two has created considerable confusion. As a result, there remains a substantial need for state courts and legislatures to create procedures for harmonizing the technical requirements imposed by federal law with the state law governing practice and procedure in divorce cases.
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