Gendreau v. Gendreau (In Re Gendreau)

HAGAN, Bankruptcy Judge,

dissenting:

My analysis of the applicable law would mandate a reversal of the order appealed. I therefore respectfully dissent. The order stating that the Appellee had a property interest in the Debtor’s pension plan was not a Qualified Domestic Relations Order; it could not create a property interest in the pension plan; and therefore it was a debt discharged in bankruptcy.

DISCUSSION

1. The Appellee Could Not Obtain an Interest in the United Pension Plans in the Absence of a QDRO.

The majority opinion properly notes that the Order did not create a debt that was nondisehargeable under section1 523 as being “in the nature of alimony, maintenance, or support.” 11 U.S.C. § 523(a)(5)(B). The Order constituted a property settlement. “Property settlements ... are dischargeable in bankruptcy.” E.g., Stedman v. Pederson (In re Pederson), 875 F.2d 781, 784 (9th Cir.1989), overruled on other grounds, Farrey v. Sanderfoot, 500 U.S. 291, 111 S.Ct. 1825, 114 L.Ed.2d 337 (1991). In Pederson, the Ninth Circuit Court of Appeals relied in part on this provision to permit the debtor to avoid a lien securing a property settlement obtained through a divorce.

Because the award was not in the nature of alimony, maintenance or support, it would have been dischargeable in bankruptcy under section 523(a)(5). Allowing Pederson to avoid a lien securing such a dischargeable property settlement is thus consistent with Congress’s policy “that property settlements should be treated the same as other debts in bankruptcy.”

*806875 F.2d at 784 (quoting Boyd v. Robinson, 741 F.2d 1112, 1116 (8th Cir.1984) (Ross, J., dissenting)).

This case therefore turns upon whether the Appellee has a presently vested property interest in the pension plans, or if her right to obtain such a property interest is a “debt” within the meaning of the Bankruptcy Code. If it is a debt, it will be discharged. 11 U.S.C. § 727(b).

2. The ERISA Anti-Alienation Provision.

It is undisputed that the United pension plans are subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), Pub.Law 93^06, 88 Stat. 829, as amended, 29 U.S.C. § 1001 et seq. Section 1056 of Title 29, United States Code, provides that “[e]aeh pension plan shall provide that benefits provided under the plan may not be assigned or alienated.” 29 U.S.C. § 1056(d)(1); see also 26 U.S.C. § 401(a)(13)(A). This section is expressly applicable to domestic relations orders:

Paragraph (1) shall apply to the creation, assignment, or recognition of a right to any benefit payable with respect to a participant pursuant to a domestic relations order, except that paragraph (1) shall not apply if the order is determined to be a qualified domestic relations order. Each pension plan shall provide for the payment of benefits in accordance with the applicable requirements of any qualified domestic relations order.

29 U.S.C. § 1056(d)(3)(A); see also 26 U.S.C. § 401(a)(13)(B). A “domestic relations order” is defined as:

any judgment, decree, or order (including approval of a property settlement agreement) which—
(I) relates to the provision of child support, alimony payments, or marital property rights to a spouse, former spouse, child, or other dependent of a participant, and
(II) is made pursuant to a State domestic relations law (including a community property law).

29 U.S.C. § 1056(d)(3)(B)(ii);' see also 26 U.S.C. § 414(p)(l)(B). It is undisputed that the Order is a “domestic relations order.”

A QDRO is defined by 29 U.S.C. § 1056 in the following manner:

(i) the term “qualified domestic relations order” means a domestic relations order—
(I) which creates or recognizes the existence of an alternate payee’s right to, or assigns to an alternate payee the right to, receive all or a portion of the benefits payable with respect to a participant under a plan, and
(II) with respect to which the requirements of subparagraphs (C) and (D) are met[.]

29 U.S.C. § 1056(d)(3)(B)(i); see also 26 U.S.C. § 414(p)(l)(A). The plan administrator is charged with initial responsibility for determining whether an order is a QDRO. 29 U.S.C. § 1056(d)(3)(G), (H); 26 U.S.C. § 414(p)(6), (7).

These sections “supersede any and all State laws insofar as they may now or hereafter relate to any employee benefit plan....” 29 U.S.C. § 1144(a). That section goes on to clarify the nature of ERISA’s preemption of state law, providing in part that:

For purposes of this section:
(1) The term “State law” includes all laws, decisions, rules, regulations, or other State action having the effect of law, of any State....
(2) The term “State” includes a State, any political subdivisions thereof, or any agency or instrumentality of either, which purports to regulate, directly or indirectly, the terms and conditions of employee benefit plans covered by this subehapter.

29 U.S.C. § 1144(c). QDRO’s are expressly excepted from preemption. 29 U.S.C. § 1144(b)(7).

3. The Order Is Not A QDRO.

The majority opinion correctly concedes that the Order is not a QDRO. As noted, a domestic relations order must meet the requirements of two subparagraphs to be a *807QDRO. 29 U.S.C. § 1056(d)(3)(B)(i)(II); see also 26 U.S.C. § 414(p)(l)(A)(ii). These sub-paragraphs provide:

(C) A domestic relations order meets the requirements of this subparagraph only if such order clearly specifies—
(i) the name and the last known mailing address (if any) of the participant and the name and mailing address of each alternate payee covered by the order,
(ii) the amount or percentage of the participant’s benefits to be paid by the plan to each such alternate payee, or the manner in which such amount or percentage is to be determined,
(iii) the number of payments or period to which such order applies, and
(iv) each plan to which such order applies.
(D) A domestic relations order meets the requirements of this subparagraph only if such order—
(i) does not require a plan to provide any type or form of benefit, or any option, not otherwise provided under the plan,
(ii) does not require the plan to provide increased benefits (determined on the basis of actuarial value), and
(iii) does not require the payment of benefits to an alternate payee which are required to be paid to another alternate payee under another order previously determined to be a qualified domestic relations order.

29 U.S.C. § 1056(d)(8)(C), (D); see also 26 U.S.C. § 414(p)(2), (8).

It is no accident that ERISA requires that the order “clearly speciffy]” certain information. 29 U.S.C. § 1056(d)(3)(C) (emphasis added); see also 26 U.S.C. § 414(p)(2) (same).

The statutory language is explicit and emphatic. The purpose is to reduce the expense of ERISA plans by sparing plan administrators the grief they experience when because of uncertainty concerning the identity of the beneficiary they pay the wrong person, or arguably the wrong person, and are sued by a rival claimant.

Metropolitan Life Ins. Co. v. Wheaton, 42 F.3d 1080, 1084 (7th Cir.1994). “[T]he ... requirement that certain facts be specified clearly serves the purpose of aiding plan administrators in determining whether certain domestic relations orders are covered by the limited exception to the antialienation and preemption rules.” Hawkins v. Commissioner of Internal Revenue, 102 T.C. 61, 74-75, 1994 WL 26316 (1994). See also S.Rep. No. 98-575, 98th Cong., 2d Sess. 19, reprinted in 1984 U.S.C.C.A.N. 2547, 2565 (guidelines to determine whether the QDRO exception to the anti-assignment provision applies are “necessary” “[i]n order to provide rational rules for plan administrators”.)

“[W]e conclude that a QDRO should be ‘clear and specific’ and not ‘left to determination by inference or conjecture.’ To allow otherwise would be to spawn again ‘a relentless stream of litigation’.” Hawkins, 102 T.C. at 73, 1994 WL 26816. Among other things, a QDRO must clearly specify either the amount or percentage of benefits to be paid to the alternate payee, or the method by which that amount or percentage is to be calculated. 29 U.S.C. § 1056(d)(3)(C)(ii); see also 26 U.S.C. § 414(p)(2)(B) (same). The terms of the Order by no means met this requirement, for reasons discussed in a footnote.2

*808Despite the concession that the Order does not constitute a QDRO, the majority opinion characterizes the deficiencies in the Order as being “technical” in nature, and even suggests that the requirements were peculiar to the plan administrator. The requirements are not “technical” in the sense of being mere details. They are the defining characteristics of a QDRO, and compliance is mandatory.

If. A Domestic Relations Order That Is Not A QDRO Cannot Create A Property Interest In An ERISA-Qualified Pension Plan.

The critical issue, therefore, is whether a domestic relations order that is not a QDRO could nonetheless act to transfer a property interest in an ERISA pension plan. The majority opinion correctly notes that it cannot. In Ablamis v. Roper, 937 F.2d 1450 (9th Cir.1991), a husband owned a pension plan in which the wife allegedly had a community property interest. The wife died, leaving her share of the community property to a trust. The question presented was whether a nonparticipant spouse could bequeath an interest in the pension plan.

The Ninth Circuit Court of Appeals held such a transfer was not permitted, as the provisions of ERISA preempted any state law permitting such a transfer. The only possible exception to the anti-alienation provision of 29 U.S.C. § 1056(d)(1) was a QDRO. 937 F.2d at 1454. The Court of Appeals noted that the provisions regarding QDRO’s had been added by the Retirement Equity Act of 1984 (“REA”), Pub.Law 98-397, 98 Stat. 1426. 937 F.2d at 1453. After an extensive discussion of the authorities, the court summarized its conclusion as follows:

Given the specific language of ERISA, the legislative history of REA, and the Supreme Court’s clear holdings regarding the applicability of anti-assignment provisions to spousal transfers, we have no doubt whatsoever that § 1056(d) of ERISA is generally applicable to transfers involving spouses and necessarily preempts all orders relating to such transfers that do not fall within the specific and limited QDRO exception set forth in REA. Orders that do not qualify under that exception contravene the direct language of ERISA’s anti-assignment provision.

937 F.2d at 1459.

One of the cases relied upon by Ahlamis is Guidry v. Sheet Metal Workers Nat’l Pension Fund, 493 U.S. 365, 110 S.Ct. 680, 107 L.Ed.2d 782 (1990). There, a union official-had embezzled funds from the union. The union obtained a constructive trust against *809the official’s pension plan. The Supreme Court held that the constructive trust violated the anti-alienation provision of ERISA. Noting that writs of garnishment against an ERISA pension plan are proscribed by the anti-alienation provision, the Court held: “We see no meaningful distinction between a writ of garnishment and the constructive trust remedy imposed in this case. That remedy is thereby prohibited by § 206(d)(1) [29 U.S.C. § 1056(d)(1) ] unless some exception to the general statutory ban is applicable.” 493 U.S. at 372, 110 S.Ct. at 685. The Court held there was no general equitable exception to the anti-alienation provision. 493 U.S. at 376-77, 110 S.Ct. at 687. “Section 206(d) [29 U.S.C. § 1056(d) ] reflects a considered congressional policy choice.... If exceptions to this policy are to be made, it is for Congress to undertake that task.” 493 U.S. at 376, 110 S.Ct. at 687 (footnote omitted). The Supreme Court later cited Guidry as demonstrating that the Court “vigorously has enforced ERISA’s prohibition on the assignment or alienation of pension benefits, declining to recognize any implied exceptions to the broad statutory bar.” Patterson v. Shumate, 504 U.S. 753, 760, 112 S.Ct. 2242, 2247, 119 L.Ed.2d 519 (1992).

5. Summary: The Appellee Had A Claim Against The Debtor That Was Discharged.

In my opinion, this settles the matter. In the divorce, the Appellee had a right to obtain a portion of the Debtor’s property. This was a “claim” under section 101(5). The State court attempted to award a property interest in the Debtor’s pension plans as part of the property settlement, but it failed to do so. On the petition date, the Appellee’s right to obtain a property interest in the Debtor’s pension plans was no different from an unsecured judgment creditor’s right to levy against a judgment debtor’s property. Under section 524, that right was discharged.

The majority opinion reaches a different result, contending that (1) the Debtor’s property interest in the pension plans had been limited by the award to the Appellee, and (2) the Appellee’s right to a portion of the pension plans was not a “claim.” Both of these arguments are flawed.

6. Neither The Order Nor ERISA Limited The Debtor’s Property Interest In The Pension Plans.

The larger portion of the majority opinion is devoted to the assertion that the Debtor has no property interest in that portion of the United pensions awarded to the Appellee. Because “the Debtor’s interest in the United pension plan[s] was limited under the state court order and the ERISA statute,” the majority opinion contends, “on the petition filing date the Debtor was entitled to only a percentage of the pension funds, with the remaining portion of the pension[s] subject to the Appellee’s right to obtain a QDRO.” I disagree.

The majority opinion first contends that two provisions of the Order restricted the Debtor’s property interest in the pension plans, or otherwise limited the Debtor’s access to the plans. The Order provided that (1) the amounts awarded to the Appellee were to be separately accounted for until the Appellee received her benefits; and (2) the benefits awarded by the Order could not be transferred, voluntarily or involuntarily, until distributed to the Appellee.

These terms of the Order are irrelevant, since they have no legal effect. As already noted, ERISA supersedes state law, meaning any “decisions ... or other State action having the effect of law” issued by any state “instrumentality ... which purports to regulate, directly or indirectly, the terms and conditions” of an ERISA-qualified pension plan. 29 U.S.C. § 1144(a), (c)(1), (c)(2). A segregation requirement did apply temporarily (see the discussion beginning in the next paragraph); however, this temporary restriction was in no way a product of the Order, but only of ERISA, and the Order was ineffective to extend the restriction in any manner.

The majority opinion next turns to several provisions of ERISA that allegedly restricted the Debtor’s property interest in the pension plans. During the period where a plan administrator or court of competent jurisdiction is determining whether an order qualifies as *810a QDRO, the majority opinion notes, the plan administrator is required to segregate in a separate account funds that would have been payable to the alternate payee if the order in fact is a QDRO. By this the majority opinion suggests that the existence of the Order caused ERISA to limit the Debtor’s property interest in the pension plans, even though the Order was not a QDRO.

I cannot agree with this conclusion. If an order presented to a plan administrator is determined not to be a QDRO (or if 18 months elapse from the time benefits would first be payable under the order), the duty to segregate is terminated and the plan administrator must pay such funds over to the plan participant.3 Thus, the segregation of funds does not protect alternate payees whose order does not qualify as a QDRO. Even alternate payees with QDRO’s only receive protection if the QDRO issue is resolved within 18 months.

This provision demonstrates that ERISA does not limit the plan participant’s property rights in the absence of a QDRO. Limited segregation4 is provided as a protection against irreparable harm for alternate payees who have a QDRO. Alternate payees whose order does not qualify as a QDRO do not receive the benefit of this minimal protection. ERISA does not limit the Debtor’s property interest in the pension plans, as the majority opinion contends; these provisions again demonstrate that the Debtor’s property interest in the pension plans is unlimited in the absence of a QDRO.

Moreover, the “segregated fund” argument would not affect the result here even if the logic of the argument were accepted. It appears from the record that the Debtor was not receiving plan benefits during the time that the plan administrator was evaluating whether the Order was a QDRO. Thus, the plan administrator would not have segregated any benefits for the Appellee. Even if plan benefits had been segregated, that segregation terminated approximately six months before the debtor filed bankruptcy, when the plan administrator rejected the order as a QDRO. With no funds segregated on the petition date, ERISA neither created nor recognized any limitation on the Debtor’s interest in the United pension plans.5

The restrictions set forth in the Order were preempted by ERISA, and of no legal effect. Contrary to the majority opinion’s suggestion, ERISA itself demonstrates that alternate payees receive no protection in the absence of a QDRO. Even if the logic of the majority opinion’s argument was accepted, no portion of the Debtor’s pension plans was subject to segregation on the petition date. I therefore must reject the majority opinion’s conclusion that the Debtor’s property interest in the pension plans was limited on the petition date.

7. The Appellee’s Right To Plan Benefits Was A “Claim” Against The Debtor.

The majority opinion also contends that the Appellee did not have a claim against the Debtor, because the obligation to pay pension benefits was not due at the time the Debtor filed bankruptcy. In support, the majority *811opinion cites Teichman v. Teichman (In re Teichman), 774 F.2d 1395 (9th Cir.1985), and the alternative holding in Bush v. Taylor, 912 F.2d 989 (8th Cir.1990). This position contradicts the plain language of the statutory definition of “claim,” and fails to properly interpret either Teichman or Bush, both of which were non-ERISA cases where a property interest had been created in the pension plan prepetition.

The majority opinion provides a quite thorough discussion of the definition of “claim,” noting the breadth that is accorded that term. I would further note that the term “claim” expressly includes “unmatured” rights to payment. 11 U.S.C. § 101(5)(A). “Claim” also includes “contingent” rights to payment, id, meaning a debt ‘“which the debtor will be called upon to pay only upon the occurrence or happening of an extrinsic event which will trigger the liability of the debtor to the alleged creditor.’ ” Fostvedt v. Dow (In re Fostvedt), 823 F.2d 305, 306 (9th Cir.1987) (quoting Brockenbrough v. Commissioner, 61 B.R. 685, 686 (W.D.Va.1986)) (interpreting 11 U.S.C. § 109(e)). Thus the plain language of the statutory definition of “claim” includes obligations where payment . is not yet due. By holding that the Appellee has no “claim” because pension benefits will only be paid in the future, the majority opinion effectively allows a debtor’s unmatured obligations to pass through bankruptcy without being discharged — a radical narrowing of the scope of bankruptcy relief.

A closer examination of Teichman and Bush demonstrates that neither ease reached this result. In Teichman, the Ninth Circuit Court of Appeals addressed the question of whether a husband could discharge through bankruptcy the obligation to convey a percentage of his military pension to his former wife. Unlike here, however, the wife had a perfected property interest in half the pension from the effective date of the state court’s order. “The district court correctly held that under the dissolution decree, the wife has an ownership interest in forty-three percent of the retirement fund.” 774 F.2d at 1398. However, the state court could not order the United States to make direct payments to the wife of her share; instead, it had to order the husband to turn over the wife’s share of the payments after the husband received each check. 774 F.2d at 1398.

For this reason, the obligation to turn over the proceeds was not a debt. Each check the husband received from the pension, although made payable to him, in fact contained the wife’s proceeds. The husband had no property interest in the wife’s share of the proceeds. The obligation to pay the wife was not a payment of a debt owing the wife, but a transfer of the wife’s property to her possession. This obligation arose only upon the receipt of the check, and therefore was not a debt. 774 F.2d at 1398.

Bush v. Taylor, 912 F.2d 989 (8th Cir. 1990), is distinguishable for exactly the same reasons. In Bush, the wife was awarded a one-half interest in the husband’s government pension plan. 912 F.2d at 990. As in Teichman, the government mailed a cheek for the full amount each month to the husband, who was then obligated to pay over to the wife her portion of the check. 912 F.2d at 990. (The obligations between the husband and wife were later modified in a manner not relevant here.) The husband subsequently filed a petition for relief in bankruptcy. The Eighth Circuit held, in an alternative holding relying upon Teichman, that the bankruptcy discharge had no effect on the husband’s obligation to remit the wife’s portion of future pension payments, because those payments were not yet due and payable. 912 F.2d at 993.

In both Teichman and Bush the wife had obtained a property interest prepetition, through the state court’s order dividing the community property. Neither case involved ERISA, so the state court order was immediately effective in this regard. In the present case, the Order was ineffective to create the property interest found in Teichman and Bush, because the Order was not a QDRO. The majority opinion misapplies Teichman and Bush to undercut the plain definition of “claim,” a result that neither court intended.6

*812The majority opinion also relies upon two lower court decisions. Bigelow v. Brown (In re Brown), 168 B.R. 381 (Bankr.N.D.Ill.1994); Long v. Donahue (In re Long), 148 B.R. 904 (Bankr.W.D.Mo.1992).

In Long, the court cited the statutory definitions of “debt” and “claim,” and then stated that the former spouse “has something other than a right to payment from the Debtor or his property.” 148 B.R. at 908. The court then stated:

As discussed above, a domestic relations order not in the form of a QDRO does not create an enforceable right to benefits against an ERISA-qualified pension; therefore, Ms. Donahue’s right to obtain a QDRO can not be classified as a debt. The Decree of Dissolution gave Ms. Donahue a right to obtain the QDRO and transfer legal ownership of her portion of Debt- or’s pensions awarded as marital property.-

148 B.R. at 908. In other words, the Long court held that since there is no enforceable right to payment in the absence of a QDRO, there is no “debt.”

“To hold that a claim for contribution arises only when there is an enforceable right to payment appears to ignore the breadth of the statutory definition of ‘claim.’ ” California Dep’t of Health Services v. Jensen (In re Jensen), 995 F.2d 925, 929 (9th Cir.1993) (rejecting contention that liability for environmental contamination was not a “claim” until response costs had been incurred). Although a right to payment is unenforceable in the absence of a QDRO, this does not mean that the Appellee has no right to payment. “Right to payment” is not determined by the creditor’s ability to immediately levy on property without any further court action, but rather on the creditor’s legal right to obtain payment. As previously noted, “claim” includes both contingent and unmatured obligations. An unsecured creditor without a judgment has a “claim,” even though the creditor has no current right to garnish the debtor’s wages or levy against the debtor’s property. 11 U.S.C. § 101(5)(A) (“whether or not such right is reduced to judgment, ... unliquidated, ... [or] disputed.”). The Appellee has both a right to payment and a state court judgment recognizing that right. The Appellee’s right to obtain a QDRO is analogous to a judgment creditor’s right to attach the debtor’s property — a final step necessary to actually obtain satisfaction of the right to payment.

Long attempted to distinguish Guidry, holding a constructive trust could be imposed because the nondebtor spouse had a right to obtain a QDRO. 148 B.R. at 909. Guidry expressly stated that a constructive trust could not be imposed unless an exception to the anti-alienation provision applied. 493 U.S. at 372, 110 S.Ct. at 685. Unqualified domestic relations orders are not excepted from the anti-alienation provision.

In Brown, the court held that a dissolution decree immediately divides the property, with the nondebtor spouse obtaining an ownership interest. 168 B.R. at 334-35. The debtor spouse holds the nondebtor’s interest in the pension plan in constructive trust. 168 B.R. at 335. “In fact, upon entry of the divorce judgment, the benefits became the sole and separate property of the Plain-tiff_ The QDRO merely served to enforce her preexisting property rights in the pension.” Id. (citation omitted). The court noted the ERISA anti-alienation provision, but stated: “[A]lthough the Plaintiff had no recognizable legal right under ERISA to the debtor’s pension benefits because she was unable to obtain the QDRO prepetition, the Plaintiff did have an equitable interest in the Debtor’s pensions arising from the entry of the decree of dissolution.” 168 B.R. at 336 n. 6 (emphasis in original). Brown simply begs the question, stating that a constructive trust is created even though Guidry says it cannot be, and holding that an equitable property *813interest exists despite the plain language of the anti-alienation provision.7

8. ERISA Preemption Conditions General Statements of The Law Regarding Property Rights.

In support of its conclusion that the award of property was effective in the absence of a QDRO, the majority opinion also cites to, or quotes from, numerous cases involving state law. The majority opinion cites Keller v. Keller (In re Keller), 185 B.R. 796, 799 (9th Cir. BAP 1995), for the proposition that when a debtor’s ultimate right to receive property is measured by or dependent upon orders which would be issued by a state court, the bankruptcy estate is subject to these rights and the bankruptcy filing cannot enlarge them. Here it is the Appellee, not the Debt- or, whose ultimate right to receive property is measured by or dependent on a state court order. Regardless, however, Keller is distinguishable, as it involved property that was in custodia legis on the date of the bankruptcy petition.

The majority opinion later cites both Keller and Paderewski v. Barrett (In re Paderewski), 564 F.2d 1353 (9th Cir.1977), for the proposition that the divorce decree conclusively established the property interests of the Debtor and the Appellee. I have no disagreement with the proposition that state law usually controls such matters. However, neither Keller nor Paderewski involved ERISA, nor do they suggest that bankruptcy courts should ignore an express federal preemption statute when evaluating property rights. The majority opinion uses Keller and Paderewski to avoid the ERISA preemption issue, rather than address it.

9. The Legislative History Does Not Support A Rejection of ERISA’s Plain Language.

The majority opinion contends that its result is consistent with the legislative history of 29 U.S.C. § 1056, noting that one purpose of the QDRO exception was to safeguard the financial security of former spouses of plan participants. Where the statute is clear, there is no need to inquire into the legislative history. See, e.g., Patterson v. Shumate, 504 U.S. 753, 761, 112 S.Ct. 2242, 2248, 119 L.Ed.2d 519 (1992). ERISA plainly and unambiguously provides that unqualified domestic relations orders do not create any property interest. “Domestic relations order” is a defined term in ERISA, yet Congress excepted from the anti-alienation provision only the subcategory of qualified domestic relations orders. Congress clearly foresaw that there would be domestic relations orders that were not qualified, and directed that those orders were to be of no effect. E.g., Ablamis, 937 F.2d at 1458 (“Thus, it is readily apparent that transfers pursuant to .state domestic relations laws or rules not exempted under the QDRO exception are governed by the anti-assignment provision.” (emphasis in original)). It is difficult to imagine Congress speaking more clearly on the issue. A domestic relations order that is not a QDRO does not create any property interest in an ERISA-qualified pension plan.8

The Supreme Court recognized this when it warned, in the specific context of the ERISA anti-alienation provision, against the creation of equitable exceptions to unqualified legislative requirements or prohibitions.

The creation of such exceptions, in our view, would be especially problematic in *814the context of an antigarnishment provision. Such a provision acts, by definition, to hinder the collection of a lawful debt. A restriction on garnishment therefore can be defended only on the view that the effectuation of certain broad social policies sometimes takes precedence over the desire to do equity between particular parties. It makes little sense to adopt such a policy and then to refuse enforcement whenever enforcement appears inequitable.

Guidry, 493 U.S. at 376-77, 110 S.Ct. at 687 (emphasis in original).

The majority opinion also raises the spec-tre of debtors manipulating the time of filing bankruptcy to deprive spouses of an award of pension benefits. There is no basis for this fear. Section 523 was amended in 1994 to make property settlements nondischargeable in bankruptcy. Bankruptcy Reform Act of 1994, Pub.L. No. 103-394, § 304(e), 108 Stat. 4106, 4133 (1994), codified at 11 U.S.C. § 523(a)(15). This amendment applies to all bankruptcy cases filed after October 22, 1994. Id., § 702(b)(1), 108 Stat. at 4150. Only cases filed before that date would be affected by this decision.

CONCLUSION

The Order was not a QDRO, did not create a property interest, and therefore is a dis-chargeable debt. I would REVERSE the Bankruptcy Court’s award of summary judgment to the Appellee.

. Unless otherwise noted, all references to "section” are to the respective section of the Bankruptcy Code, Title 11, United States Code.

. The following are some of the more serious ambiguities found in the Order. First, the Order contains two conflicting formulae for computing the benefits to be paid to the Appellee. Paragraph 1 of the Order provides on page 2 that "the Defendant [Appellee] is entitled to one-half of the marital shares, that being 50% of 13.71% of each of the aforesaid properties.” Paragraph 2 contains a second formula by which the Appel-lee's interest is calculated. The denominator is the total number of months of the Debtor's total length of employment until he retires and begins to receive his pension benefits. The numerator is the total number of months the Appellee and the Debtor were married. This fraction is converted to a percentage, of which the Appellee is entitled to receive one half. The Order does not indicate which formula the plan administrator should use.

This is particularly problematic, since the second formula reaches a significantly different result from the first. Interpreting the second formula according to its most probable meaning gives the following result, based on facts found in the Order. The marital share of the property covers the period from December 3, 1985, to *808August 16, 1990, a total of 57 months. The Order states the Debtor began working at United in August, 1966, and is eligible to retire with benefits on April 1, 1999, a total length of employment of 392 months. If these figures are inserted into the fractional formula, the result is 57/392 or 14.54%. This is significantly higher than the 13.71% figure used in paragraph 1. Differing figures may be obtained depending on how partial months are counted; however, none of these figures equals 13.71%, and the Order does not specify how partial months should be counted.

Other ambiguities exist. As noted, paragraph 1 states that "the Defendant [Appellee] is entitled to one-half of the marital shares, that being 50% of 13.71% of each of the aforesaid properties.” This language could be read to say either that the award is of one-half of 13.71% of the plans, or of one-half of 50% of 13.71% of the plans.

The denominator of the second formula in paragraph 2 on page 2 is ambiguous. The Order provides the Appellee may elect to receive benefits as of the earliest date the Debtor could retire. The Debtor has already passed his early retirement date, so pension benefits to the Appellee would be payable immediately. However, the Debtor has not retired. Because the denominator of the second formula is the number of months until the Debtor's retirement, the denominator cannot be calculated. (It should be noted that the record includes the exceptions made by counsel to entry of the Order, and that Debtor's counsel specifically excepted to the Order on precisely this ground.)

Paragraph 1 on page 5 of the Order confuses the situation further. It states the Appellee is awarded "[a] sum equal to fifty percent (50%) of the amount allocated according to the formula described hereinabove.” Two ambiguities exist. First, as noted, this paragraph does not specify whether the formula is the percentage described in paragraph 1, or the fractional percentage described in paragraph 2. Second, this paragraph can be read as further halving the sums already halved in both the previous formulae. For example, the second, fractional formula provides that the Appellee is entitled to one-half of the fraction. Paragraph 1 on page 5 would suggest the Appel-lee was entitled to only one-half of that amount, or one-quarter of the fraction.

. The relevant portion of ERISA provides:

(iii) If within 18-month period described in clause (v)
(I) it is determined that the order is not a qualified domestic relations order, or
(II) the issue as to whether such order is a qualified domestic relations order is not resolved,
then the plan administrator shall pay the segregated amounts (including any interest thereon) to the person or persons who would have been entitled to such amounts if there had been no order.

29 U.S.C. § 1056(d)(3)(H)(iii). See also 26 U.S.C. § 414(p)(7)(C) (same).

. Segregation applies only to benefits that would have been paid to the alternate payee during the time the plan administrator is considering whether the order is a QDRO. See 29 U.S.C. § 1056(d)(3)(H)(i) (during the time the plan administrator is determining whether an order is a QDRO, "the plan administrator shall separately account for the amounts ... which would have been payable to the alternate payee during such period if the order had been determined to be a qualified domestic relations order.”) (emphasis added); 26 U.S.C. § 414(p)(7)(A) (same).

. Note in addition that the limitation on the Debtor’s property interest in the pension plans would not be the full amount awarded the Appel-lee, but only the segregated amounts, i.e., those benefits that would have been payable until the QDRO issue was resolved.

. The majority opinion asserts that it relies upon Teichman and Bush for the proposition that the Appellee does not have a claim against the Debt- or. I cannot agree. The Debtor has a valuable *812property interest in the pension plans; the Order itself is premised on that fact. The Appellee currently lacks any property interest in the Debt- or’s pension plans, but seeks to use her unsecured judgment to obtain a portion of the Debt- or’s property. This is a claim against the Debtor. See 11 U.S.C. § 102(2) (rule of construction in Title 11 is that "'claim against the debtor’ includes [a] claim against property of the debtor”); Johnson v. Home State Bank, 501 U.S. 78, 84-86, 111 S.Ct. 2150, 2154-55, 115 L.Ed.2d 66 (1991) (mortgagee’s right to foreclose is a claim, even though the debtor’s personal liability has been discharged).

. The majority opinion briefly cites Zick v. Zick (In re Zick), 123 B.R. 825 (Bankr.E.D.Wis.1990). Zick also involved a QDRO obtained postpetition. See 123 B.R. at 828. The Zick court merely made the conclusoiy allegation that the state court’s award gave the wife a property interest in the pension plan, without ever recognizing or addressing the ERISA anti-alienation provision. 123 B.R. at 829.

. The legislative history of the REA amendments that added the QDRO requirements also supports this conclusion.

Under the bill, if a domestic relations order requires the distribution of all or a part of a participant’s benefits under a qualified plan to an alternate payee, then the creation, recognition, or assignment of the alternate payee’s right to the benefits is not considered an assignment or alienation of benefits under the plan if and only if the order is a qualified domestic relations order.

S.Rep. No. 98-575, 98th Cong., 2d Sess. 19, reprinted in 1984 U.S.C.C.A.N. 2547, 2565 (emphasis added).