Leighton v. Leighton
Trial court should consider unvested interest In Retirement plan. The fact that the interest is contingent does not mean that it can be ignored.
Heatwole v. Heatwole
Court has discretion in whether or not to consider non-vested pension rights.
In Re Marriage of Mack v. Mack
Court must consider unvested pension plan.
Derleth v. Cordova
Trial court reversed for not valuing the unvested portions of husband’s retirement plan where it was due to vest two weeks after the final hearing.