Trustees of the Pension Fund of Local No. One, I.A.T.S.E. v. Robbins

Background

The Trustees of the Pension Fund of Local No. One, I.A.T.S.E. (the Fund) brought an interpleader action to resolve competing claims to certain pension benefits. Dennis Robbins and Mary Ellen Sanchez were married in September 1982 and divorced in September 1992. Their divorce settlement provided that Sanchez would receive one-half of the pension benefit earned from September 13, 1982, through July 12, 1991, paid directly from the pension fund through a qualified domestic relations order (QDRO). A QDRO is a court order directing the distribution of retirement benefits to a former spouse or other recipient.

The New Jersey Superior Court entered a QDRO in 1995. It stated that Sanchez would receive 50 percent of a “marital benefit” calculated using a nine-year numerator and the total years of Robbins’s pension credit through the end of 1991. The Fund later filed this case seeking declaratory and injunctive relief concerning the portion of Robbins’s pension benefit to which Sanchez was entitled.

Motion and Positions

Robbins moved for summary judgment, which asks the court to decide a matter without a trial when there is no genuine dispute over a material fact and the moving party is entitled to judgment under the law. The Fund informed the Court that it did not oppose the motion. Sanchez filed a letter opposing it.

Court’s Analysis

The Court applied New York law. Under that law, pension benefits can qualify as marital property, and former spouses can divide those benefits through a QDRO. But a QDRO based on a settlement can convey only the rights provided in that settlement. If the QDRO is inconsistent with the settlement or divorce judgment, the settlement controls and the QDRO must be modified accordingly.

The Court determined that the divorce settlement limited Sanchez’s share to pension benefits earned during the period from 1982 through July 1991. The QDRO, however, referred to the pension benefit to which Robbins would be entitled “on his retirement.” The Court concluded that this language was ambiguous and could be read to give Sanchez a share of benefits Robbins earned through employment after 1991. Because that would provide Sanchez greater benefits than the settlement allowed, the QDRO was inconsistent with the settlement to that extent.

Ruling

Judge J. Paul Oetken granted Robbins’s motion for summary judgment. He also granted Robbins’s request to draft a proposed order directing the Fund to disburse the pension benefit consistently with the divorce settlement. The Court directed Robbins to confer with the Fund and file a proposed judgment within fourteen days addressing the allocation of funds to Robbins and Sanchez and directing the Fund to disburse those funds. The Clerk was directed to close the motion at ECF No. 29.