Maslen v. Maslen

In January 1985, Holbrook Maslen (defendant) and Eileen Maslen (plaintiff) were married. Holbrook was an airline pilot who was fully vested in two pension plans provided by his airline-company employer. The first plan was a fixed-benefit plan (FB plan) that entitled Holbrook to a fixed, lifetime monthly benefit on retirement. The benefit was entirely employer funded and was calculated as a percentage of Holbrook’s salary at the time of retirement multiplied by his months of participation in the plan. The second pension plan was a directed-account plan (DA plan) akin to an investment savings account. The employer made monthly contributions to Holbrook’s directed account in an amount equaling 9 percent of his monthly salary. On retirement, Holbrook would receive the accumulated contributions plus or minus investment gains and losses. In August 1985, Eileen filed for divorce, and the divorce was finalized in September 1987. The trial court found that the only community assets were the two pension plans. As to each plan, the court calculated Holbrook’s accrued benefits as of the date of marriage and the date of divorce and attributed the increase in benefits to the community. The court awarded Eileen a one-half share of the community portion. The court ordered the DA-plan benefits to be paid to Eileen immediately as a lump sum and the FB-plan benefits to be paid to her monthly by the plan administrator. The judgment was affirmed on appeal. Holbrook petitioned the Idaho Supreme Court for review, which the court accepted. Holbrook challenged the division of community assets, arguing that the court failed to use the time-rule method of valuation and should have ordered a lump-sum distribution of FB-plan benefits to Eileen.