LexyCorpus case page
CourtListener opinion 10732269
Date unknown · US
- Extracted case name
- pending
- Extracted reporter citation
- 207 F.3d 1143
- Docket / number
- pending
Machine-draft headnote
Machine-draft public headnote: CourtListener opinion 10732269 is included in the LexyCorpus QDRO sample set as a public CourtListener opinion with relevance to pension / defined benefit issues. The current annotation is conservative: it identifies source provenance, relevance signals, and evidence quotes for attorney/agent retrieval. It is not a Willie-approved legal headnote yet.
Retrieval annotation
Draft retrieval summary: this opinion has QDRO relevance score 5/5, retirement-division score 5/5, and family-law score 5/5. Use the quoted text and full opinion below before relying on the case.
Category: pension / defined benefit issues
Evidence quotes
QDRO“action concerning the proceeds of a life insurance policy administered by the Hartford Life and Accident Insurance Company ("Hartford Plan"). The district court held the Legal Separation Agreement ("LSA") between Kowalski and her deceased ex-husband was a Qualified Domestic Relations Order ("QDRO") under the Employee Retirement Income Security Act of 1974 ("ERISA"). The LSA provides that the decedent "shall carry and maintain a policy of life insurance in the amount of $800,000" and "name [Kowalski's minor son, E.K.] as sole beneficiary." Thus, in accordance with the LSA, the district court held E.K. had superior rights to the Hartford Pl”
pension“ust, among other requirements, "clearly specif[y]" "each plan to which such order applies." 29 U.S.C. § 1056(d)(3)(C)(iv). We require only "substantial compliance" with ERISA's specificity requirements. Hamilton v. Wash. State Plumbing & Pipefitting Indus. Pension Plan, 433 F.3d 1091, 1097 (9th Cir. 2006) 2 23-3286 (citing Trs. of Dirs. Guild of Am.-Producer Pension Benefits Plans v. Tise, 234 F.3d 415, 420 (9th Cir. 2000)). The LSA substantially complies with the specificity requirements. The purpose of these requirements is to "spar[e] plan administrators the grief they experience" due to "uncertainty conce”
ERISA“Insurance Company ("Hartford Plan"). The district court held the Legal Separation Agreement ("LSA") between Kowalski and her deceased ex-husband was a Qualified Domestic Relations Order ("QDRO") under the Employee Retirement Income Security Act of 1974 ("ERISA"). The LSA provides that the decedent "shall carry and maintain a policy of life insurance in the amount of $800,000" and "name [Kowalski's minor son, E.K.] as sole beneficiary." Thus, in accordance with the LSA, the district court held E.K. had superior rights to the Hartford Plan proceeds over the decedent's girlfriend, Valois, who is the named benefi”
domestic relations order“cerning the proceeds of a life insurance policy administered by the Hartford Life and Accident Insurance Company ("Hartford Plan"). The district court held the Legal Separation Agreement ("LSA") between Kowalski and her deceased ex-husband was a Qualified Domestic Relations Order ("QDRO") under the Employee Retirement Income Security Act of 1974 ("ERISA"). The LSA provides that the decedent "shall carry and maintain a policy of life insurance in the amount of $800,000" and "name [Kowalski's minor son, E.K.] as sole beneficiary." Thus, in accordance with the LSA, the district court held E.K. had superior rights to the Hartford Pl”
Source and provenance
- Source type
- courtlistener_qdro_opinion_full_text
- Permissions posture
- public
- Generated status
- machine draft public v0
- Review status
- gold label pending
- Jurisdiction metadata
- US
- Deterministic extraction
- reporter: 207 F.3d 1143
- Generated at
- May 14, 2026
Related public corpus pages
Deterministic links based on shared title/citation terms and QDRO / retirement / family-law retrieval scores.
Clean opinion text
NOT FOR PUBLICATION FILED
UNITED STATES COURT OF APPEALS NOV 5 2024
MOLLY C. DWYER, CLERK
U.S. COURT OF APPEALS
FOR THE NINTH CIRCUIT
HARTFORD LIFE AND ACCIDENT No. 23-3286
INSURANCE COMPANY, D.C. No.
3:21-cv-06469-RS
Plaintiff,
v. MEMORANDUM*
MARILYNE VALOIS,
Defendant-Cross-Claimant -
Appellant,
v.
HAILI KOWALSKI,
Defendant-Cross-Defendant -
Appellee.
Appeal from the United States District Court
for the Northern District of California
Richard G. Seeborg, District Judge, Presiding
Argued and Submitted October 24, 2024
San Francisco, California
Before: OWENS, SUNG, and SANCHEZ, Circuit Judges.
*
This disposition is not appropriate for publication and is not precedent
except as provided by Ninth Circuit Rule 36-3.
Marilyne Valois appeals from the district court's summary judgment in
favor of Haili Kowalski in this interpleader action concerning the proceeds of a life
insurance policy administered by the Hartford Life and Accident Insurance
Company ("Hartford Plan"). The district court held the Legal Separation
Agreement ("LSA") between Kowalski and her deceased ex-husband was a
Qualified Domestic Relations Order ("QDRO") under the Employee Retirement
Income Security Act of 1974 ("ERISA"). The LSA provides that the decedent
"shall carry and maintain a policy of life insurance in the amount of $800,000" and
"name [Kowalski's minor son, E.K.] as sole beneficiary." Thus, in accordance
with the LSA, the district court held E.K. had superior rights to the Hartford Plan
proceeds over the decedent's girlfriend, Valois, who is the named beneficiary. We
review the district court's interpretation of ERISA and summary judgment de
novo. Stewart v. Thorpe Holding Co. Profit Sharing Plan, 207 F.3d 1143, 1148
(9th Cir. 2000). We affirm.
1. Valois argues the LSA is not a QDRO because it does not clearly specify
the Hartford Plan. To be a QDRO under ERISA, a Domestic Relations Order
("DRO") must, among other requirements, "clearly specif[y]" "each plan to which
such order applies." 29 U.S.C. § 1056(d)(3)(C)(iv). We require only "substantial
compliance" with ERISA's specificity requirements. Hamilton v. Wash. State
Plumbing & Pipefitting Indus. Pension Plan, 433 F.3d 1091, 1097 (9th Cir. 2006)
2 23-3286
(citing Trs. of Dirs. Guild of Am.-Producer Pension Benefits Plans v. Tise, 234
F.3d 415, 420 (9th Cir. 2000)).
The LSA substantially complies with the specificity requirements. The
purpose of these requirements is to "spar[e] plan administrators the grief they
experience" due to "uncertainty concerning the identity of the beneficiary."
Stewart, 207 F.3d at 1150 (emphasis and citation omitted). Here, there is no
uncertainty. Although the LSA only mentions "a policy of life insurance," the
decedent had but one such policy—the one under the Hartford Plan. The LSA
clearly requires the decedent to name E.K. as the sole beneficiary on that policy.
Based on the unique facts of this case, where it is clear which plan is implicated,
the LSA substantially complies with ERISA's specificity requirements and is a
QDRO. See Hamilton, 433 F.3d at 1097 (noting the "pivotal question" for
substantial compliance is whether the DRO "clearly contains the information
specified in the statute that a plan administrator would need to make an informed
decision" (quoting Stewart, 207 F.3d at 1154)).
2. Valois also argues the LSA is not a QDRO because it increases the
payment burden on the Hartford Plan. To be a QDRO, a DRO must not "require
the plan to provide increased benefits." 29 U.S.C. § 1056(d)(3)(D)(ii). The
Hartford Plan proceeds totaled $493,000, which is less than the $800,000 policy
the decedent was obligated to maintain according to the LSA. However, the LSA
3 23-3286
is an agreement between the decedent and Kowalski, not between Kowalski and
Hartford. Nothing in the LSA requires Hartford to provide an amount greater than
$493,000. In fact, Hartford has deposited the proceeds and has been dismissed
from the underlying action. Moreover, Kowalski is not requesting more than is
allowed under the Hartford Plan. The LSA thus does not require the Hartford Plan
to provide increased benefits.
3. We affirm the district court's grant of summary judgment. Each party
shall bear its own costs on appeal.
AFFIRMED.
4 23-3286