Fredy Rivera-Santos v. Ada Elba Melendez Rivera-Santos

CourtLouisiana Court of Appeal
DecidedDecember 10, 2003
DocketCA-0003-0667
StatusUnknown

This text of Fredy Rivera-Santos v. Ada Elba Melendez Rivera-Santos (Fredy Rivera-Santos v. Ada Elba Melendez Rivera-Santos) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fredy Rivera-Santos v. Ada Elba Melendez Rivera-Santos, (La. Ct. App. 2003).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

CA 03-667

FREDY RIVERA-SANTOS

VERSUS

ADA ELBA MELENDEZ RIVERA-SANTOS

**********

APPEAL FROM THE THIRTIETH JUDICIAL DISTRICT COURT, PARISH OF VERNON, NO. 53,122 HONORABLE JOHN C. FORD, DISTRICT JUDGE

JIMMIE C. PETERS JUDGE

Court composed of Sylvia R. Cooks, John D. Saunders, and Jimmie C. Peters, Judges.

AFFIRMED AS AMENDED.

Tony C. Tillman Post Office Drawer 648 Leesville, LA 71446 (318) 239-7983 Counsel for Plaintiff/Appellant: Fredy Rivera-Santos

Scott Westerchil 101 South First Street Leesville, LA 71446 (337) 239-9076 Counsel for Defendant/Appellee: Ada Elba Melendez Rivera-Santos PETERS, J.

The issue before us concerns the determination of a divorced wife’s interest in

her former husband’s retirement benefits, insofar as they are attributable to his

employment during the existence of the community. The former husband, Fredy

Rivera-Santos, appeals the trial court’s determination that the benefits should be

partitioned according to the formula set forth in Sims v. Sims, 358 So.2d 919

(La.1978). For the following reasons, we affirm the trial court’s judgment awarding

Ms. Rivera-Santos a portion of Mr. Rivera-Santos’ retirement benefits, but amend the

judgment to partition the said benefits according to the supreme court’s instructions

found in Hare v. Hodgins, 586 So.2d 118 (La.1991).

DISCUSSION OF THE RECORD

Fredy Rivera-Santos and Ada Elba Rivera-Santos were married on June 3,

1981. Mr. Rivera-Santos began serving in the United States Army on June 28, 1981,

and, with the exception of the period of time between July 27, 1987, and January 28,

1988, he remained on active duty through August 16, 2002, the date of trial on the

issues now before this court. On March 24, 1993, Mr. Rivera-Santos filed a petition

for divorce, and the parties were divorced by judicial decree on July 27, 1993. Thus,

he acquired military retirement benefits during the existence of the community of

acquets and gains, as well as after the community dissolved.

On March 17, 2001, Ms. Rivera-Santos filed a rule to show cause, seeking

recognition of her interest in her former husband’s military retirement benefits. In

response, Mr. Rivera-Santos filed a rule to show cause, requesting that the trial court

limit his former wife’s interest in the retirement benefits based on his rank at the time

of the divorce as opposed to his rank when he ultimately retires. By a judgment

rendered August 16, 2002, and signed February 14, 2003, the trial court granted judgment in favor of Ms. Rivera-Santos. The February 14, 2003 judgment reads in

pertinent part as follows:

IT IS FURTHER ORDERED, ADJUDGED and DECREED that ADA ELBA MELENDEZ RIVERA-SANTOS, NOW MELENDEZ, has an interest in the military retirement benefits accruing to FREDY RIVERA-SANTOS as a result of his service in the United States Armed Forces, when and if they vest, as her sole and separate property, equal to the following formula: One half, multiplied by a percentage in which the numerator is 140 (months of service during marriage) and the denominator is the total months of service creditable for retirement at the time of retirement, multiplied by the military retired pay payable to a member retiring at the rank of W-2 who would have retired with twenty years service in June 2001, together with all increases that did or would have occurred, other than increases attributable to elevation in rank or services rendered after said date, plus a like percentage of all cost of living adjustment increases that accrue to said military retirement benefits hereafter. For the purpose of interpreting this Court’s intention in making the division set forth in this Order, “military retirement” means disposable retired pay as defined in 10 U.S.C. § 1408. All sums payable to ADA ELBA MELENDEZ RIVERA-SANTOS, NOW MELENDEZ as a portion of military retirement shall be payable from FREDY RIVERA-SANTOS’ disposable retired or retainer pay to the extent that it is so restricted by law.

In his sole assignment of error, Mr. Rivera-Santos contends that the trial court erred

in its calculation of the amount of his retirement benefits due his former wife.

OPINION

The trial court applied the formula enunciated by the supreme court in Sims v.

Sims, 358 So.2d 919 (La.1978), to reach its decision concerning the division of the

retirement benefits. In Sims, the supreme court established the division formula for

pension or retirement benefits as follows:

Portion of pension attributable to service during marriage x ½ x lump sum or annuity Portion of pension attributable to total service

Generally, the result of this mathematical calculation represents the amount due

2 the former spouse. However, in Hare v. Hodgins, 586 So.2d 118, 123 (La.1991), the

supreme court recognized that the Sims formula is not applicable to all pension or

retirement division situations. In Hare, the supreme court stated:

The general rules for the partition of community property, however, do not address all of the problematic ramifications of classifying, valuating and distributing each spouse’s interest in pension benefits which have been earned by one spouse partly during the marriage and partly before or after. In such cases, the pension benefits are composed of the separate property interest of the employee spouse in addition to the community interest. Furthermore, there is no custom from which rules can be derived for each particular situation. Accordingly, in the present case and others a court is bound to proceed and decide equitably to some extent, making resort to justice, reason and prevailing usages. .... [T]here will be unusual cases in which a substantial part of the increased retirement benefits earned by the employee spouse after divorce will not result from a foundation provided by prior community earnings. Fondi v. Fondi, supra; Gemma v. Gemma, supra. In such cases, the partitioning court should select a more equitable method or modify the community or marital fraction rule to attribute that part of the post-divorce increase to the employee spouse separately. Although the emerging jurisprudential precepts are not yet well defined, some factors may be identified as helpful guidelines in determining when such a modification is required.

Id. at 127-128.

The supreme court in Hare established a three-part test for the partitioning court

to apply in determining whether or not a substantial post-community increase is due

purely to personal merit. “First, the increment must represent a fairly substantial

increase in the employee spouse’s post-community earnings. Second, the increment

must not be due to a non-personal factor, such as cost-of-living raises, etc. Third, the

increment must be attributable to the employee spouse’s meritorious individual efforts

or achievements.” Id. The employee spouse has the burden of proof, and any doubt

should be resolved in favor of the community. Id. Thus, Hare recognized that in the

interest of equality and equity, a trial court has great discretion in dividing

3 community-owned pension benefits. “[If] the trial court agree[s] that the pension was

increased due to the employee spouse’s personal effort or achievement, benefits may

then be reallocated using the highest income the employee spouse would have

received under the normal course of events, including ordinary promotions and cost

increases and gains due to non-personal factors.” Id. at 128.

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Fredy Rivera-Santos v. Ada Elba Melendez Rivera-Santos, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fredy-rivera-santos-v-ada-elba-melendez-rivera-santos-lactapp-2003.