Moor-Jankowski v. Moor-Jankowski
In a matrimonial action, the plaintiff appealed an order from the Supreme Court, Westchester County, which granted the defendant’s motion for partial summary judgment, dismissing her claim for equitable distribution of his retirement funds. The parties had an antenuptial agreement stating each party would retain separate property, including increments resulting from personal efforts, and waived rights to the other's separate property. The plaintiff contended the agreement was unenforceable due to non-compliance with ERISA spousal consent provisions. The court concluded that ERISA's spousal consent provisions apply to a plan participant's current spouse, not a former spouse, and that the plaintiff had waived her interest in the pension through the antenuptial agreement. Therefore, the appellate court affirmed the order, agreeing that the funds accumulated before and after the marriage constituted the defendant's separate property.