Stiel v. Stiel
2011 Tenn. App. LEXIS 133
Tenn. Ct. App.2011Background
- Marriage lasted 14 years; Final Decree (1995) awarded Wife half of GM plan value earned during marriage.
- QDRO entered 1996, multiple versions; Amended QDRO accepted by GM Plan Administrator in 1997.
- Final Decree did not explicitly address early retirement supplements or post-retirement increases.
- Husband retired in 2009 with 30.6 years service; benefit calculated with deductions and supplements.
- Trial court held Wife entitled to post-dissolution supplements and post-retirement increases; survivorship not included; second amended QDRO entered (2010).
- Court of Appeals affirmed the trial court on all issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether early retirement supplements and post-retirement increases are included in Wife’s marital award. | Stiel contends Wife is entitled to those benefits. | Stiel contends those benefits are not part of the decree. | Included in Wife’s marital award. |
| Whether survivorship rights were included in the marital award. | Wife argues she has survivorship rights. | Husband argues no automatic survivorship rights absent explicit award. | Survivorship not automatically included. |
| Whether the non-contemporaneous QDRO affects enforceability of the award. | QDROs can implement the decree as drafted. | Delay in QDRO leads to asymmetry and potential modification issues. | Court retained and affirmed the award under the Final Decree. |
Key Cases Cited
- Cohen v. Cohen, 937 S.W.2d 823 (Tenn. 1996) (unvested benefits are marital property; defer distribution permissible)
- Pruitt v. Pruitt, 293 S.W.3d 537 (Tenn. Ct. App. 2008) (QDRO cannot substantially modify final decree; contemporaneous QDRO treated as part of judgment)
- Potts v. Potts, 790 A.2d 703 (Md. Ct. Spec. App. 2002) (survivor benefits treated as separate marital property in some jurisdictions)