Yale-New Haven Hosp. v. Nicholls, No. 13-4725 (2d Cir. 2015)
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The Hospital filed an interpleader action under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., to resolve competing claims by Barbara Nicholls and Clair Nicholls to certain funds held in the four retirement and pension plans of the late Harold Nicholls. Barbara is Harold's surviving spouse and Claire is Harold's former spouse. The district court granted summary judgment in favor of Claire because the divorce settlement agreement constitutes a qualified domestic relations order (QDRO). The court found that the divorce settlement agreement does not constitute a QDRO because the agreement fails to comply with the requirements of 29 U.S.C. § 1056(d)(3)(C); however,
the nunc pro tunc orders constitute valid QDROs that assign funds to Claire from the three retirement and pension plans named in the orders; but because the nunc pro tunc orders do not clearly specify the fourth plan, the orders do not assign funds from that plan to Claire. Accordingly, the court affirmed in part and reversed in part.
The court issued a subsequent related opinion or order on January 22, 2016.
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