Petition for Writ of Certiorari — Carmona v. Carmona

Supreme Court brief2011

Ask Donna

What actually matters in this document.

Text

Supreme Court, U.S

FILEN

10-784 UEC 9 - 7910

No OFFICE OF THE CLERK

In The

Supreme Court of the dnited States

JANIS CARMONA

Petitioner

JUDY CARMONA,

HILTON HOTELS CORPORATION RETIREMENT PLAN

Respondents

On Petition for Writ of Certiorart to the

United States Court of Appeals for the Ninth Circuct

PETITION FOR WRIT OF CERTIORARI

SCOTTLYNN J HUBBARD IV

Counsel of Record

LAW OFFICES OF LYNN

HUBBARD

12 WILLIAMSBURG LANE

CHICO, CALIFORNIA 95926

(530) 895-3252

lawofchaos@aol.com

December 9, 2010

Counsel for Petitioner

QUESTION PRESENTED

The Rooker-Feldman doctrine recognizes that

federal district courts do not have subject matter

jurisdiction to hear appeals from = state court

decisions. Precisely stated, the doctrine bars “cases

brought by state-court losers complaining of

injuries caused by state-court judgments rendered

before the district court proceedings commenced

and inviting district court review and rejection of

those judgments.” Hxxon Mobil Corp. v. Saud

Basic Inds. Corp., 544 U.S. 280, 284 (2005). A split

has developed between the Courts of Appeal,

however, about whether state court judgments over

subject matter that falls within the federal courts’

exclusive jurisdiction may be collaterally attacked

in a district court, without running afoul of the

doctrine. In an amended published opinion, the

United States Court of Appeals for the Ninth

Circuit, held that Rooker-Feldman barred ERISA

claims brought under 29 U.S.C. § 1132(a)(3), which

fall within the exclusive purview of the federal

courts under 29 U.S.C. § 1182(e)(1), because the

plaintiff failed to timely remove her original state

court divorce proceeding and a judgment had

already been entered.

The question presented is:

Whether the court of appeals correctly applied

the long-settled rule of law that, where Congress

explicitly grants exclusive jurisdiction to federal

courts, Rooker-Feldman cannot bar collateral

review of a state court order that improperly

decided a question falling exclusively within the

jurisdiction of the federal courts.

PARTIES TO THE PROCEEDINGS'!

Pursuant to Rule 14.1(b), the following list

identifies all of the parties appearing here and

before the United States Court of Court of Appeals

for the Ninth Circuit

The petitioner here, and plaintiff below, is Janis

Carmona, eighth wife to decedent Lupe Carmona

The respondents here, and defendants below,

are Judy Carmona, Lupe’s ninth wife, and the

Hilton Hotels Corporation Retirement Plan

Nevada _ Resort Association Internationa)

Alhance of Theatrical and Stage Employees Local

720 Pension Trust filed a cross-claim against Judy

Carmona, who was the cross-defendant to that

action.

| Because they share the same last name, th

Carmonas - viz., Lupe, Janis, and Judy © will be referred to by

their first names in this petition

Lil

TABLE OF CONTENTS

Question Presented

Parties to the Proceedings | ,

Table of Contents ... 1

Table of Authorities \

Petition for Writ of Certiorari

Opimons Below.

Statement Of Jurisdiction

Statutory and Regulatory Provisions

Statement of Case /

Summary of Argument. : | 14

Argument... e ears 16

| Despite this Court’s efforts in Mxxon Mobil

Corp., a Circuit-split remains over whether

the Rooker-Feldman doctrine bars a “state

court loser” from collaterally attacking a

state court judgment in the United States

District Court, when Congress grants

federal courts exclusive jurisdiction over

the subject matter of that judgment. 16

I}. The Ninth Circuit created a circuit-split. by

requiring ERISA participants and

beneficianies to remove their garden-variety

divorce proceedings (within thirty-days of

receiving the complaint) to federal court,

regardless of whether the only federal issue

is a potential conflict preemption defense, or

lose the nght to proceed in federal court. with

Conclusion

Appendix

Appendix A

Appendix B:

Appendix C:

Appendix D:

Appendix It:

Appendix F:

any future ERISA claim. RUM padre Pee ne a9

yA

Ninth Circuit Amended

Opinion (May 4, 2010)............ La

District Court Memorandum,

(Sept. JO, ZUGD)............0........ 448

Nevada Supreme Court Order,

Gjct. Zi. ZOU) ..cecevess. oe.

Ninth Circuit Order re

Rehearing,

(Sept. 10, 2010).....................65a

Ninth Circuit Order Staying

Mandate,

ae 4 eS |) ee 68a

Lupe Complaint for Divorce,

PERG ERED oikicwcsnccsvuney vaceu: 70a

Appendix G:

Janis Answer to Complaint

and Counter-claim,

CPR Be, Be bei ciscascsscassincnccees 76a

TABLE OF AUTHORITIES

Cases

1975 Salaried Retirement Plan for Eligible

Kmployees of Crucible, Inc. v. Nobers,

968 F.2d 401 (8rd Cir. Pa. 1992) ...

Aetna Health Inc. v. Davila,

542 U.S. 200 (2004)............ a

Beneficial Nat'l Bank v. Anderson,

539 U.S. 1 (2008)... cccccccccccceceeeee.

Carmona v. Carmona,

2003 WL 25914267 (Nev. Oct. 21, 2003)

Carmona v. Carmona,

541 U.S. 989 (April 19, 2004).

Carmona v. Carmona,

044 F.3d 988 (9 Cir. Sept. 17, 2008)

Vv vy m

Carmona uv. Carmona,

603 F.3d 1041 (9th Cir. May 4, 2010) ..

Carmona v. Hilton Hotels Corp.

Retirement Plan,

2005 WL 6563968 (D.Nev. Sept. 30, 2005) ...

Caterpillar, Inc. v. Williams,

BS UTES. TH CI io nsevncinsiccnecsesscsece: ineeaes

District of Columbia Court of Appeals v.

Feldman,

BD EF. BG Co csncvccecenicncennss

1, 10

Vi

Exxon Mobil Corp. v. Saudt Basic Inds. Corp.,

544 U.S. 280 (2005)............... 1, 12, 16,

Franchise Tax Bd. v.

Construction Laborers Vacation Trust.

OS Oe eee.

General Motors Corp. v. Buha,

623 F.2d 455 (6th Cir. 1980)

Gilbert v. Burlington Industries, Inc.,

765 F.2d 320 (2nd Cir. 1985)

Henrichs v. Valley View Dev

474 F.3d 609 (9th Cir. 2007)

Huffman v. Pursue, Ltd.,

420 U.S. 592 (1975)...

In re Ferren,

203 F.3d 559 (8th Cir. 2000).

In re Gruniz,

202 F.3d 1074 (9th Cir. 2000) .... ¥?

In re James,

940 F.2d 46 (8rd Cir. 1991)

Lance v. Dennis,

546 U.S. 459 (2006)......

Leonelli v. Pennwalt Corp.,

887 F.2d 1195 (2nd Cir. 1989)...........

Louisville & Nashville R.R. v. Mottley,

911 U.S, 149 (1908) ..noncncceccccsscsssoscocsess:

20

i

Noel v. Hall,

341 F.3d 1148 (9th Cir. 2003) 13

Rivet v. Regions Bank,

522 U.S. 470 (1988) . 19, 20

Rooker v. Fidelity Trust Co.,

263 U.S. 413 (1923) ..cccccccccccceee: | 1G

Singleton v. Fifth Third Bank (In re Singleton)

230 B.R. 533 (B.A.P. 6th Cir. 1999). ... 7

Total Plan Services v.

Texas Retailers Association,

925 F.2d 142 (5th Cir. 1991).. ) 14

Verizon Md., Inc. v. Pub. Serv. Comm'n of Md.,

ee OF, GO CI rsdn scvcsesicnsaces: iets vee, 1’

Yoon v. Fordham Univ. Faculty & Admin. Ret.

Plan, 263 F.3d 196 (2nd Cir. 2001)........ ee

Statutes

28 U.S.C. § 1257. 16, 18 4

> AUR 8 eS }. * PR aD ras ae 19

28 U.S.C. § 1441 (a) .eecccccccecceeeeeee- oe yee 19

Le Fem SO eee: ee

28 U.S.C. § 1446(b)....... cradsetaiecnecseeseac ll

28 U.S.C. § 1254 (1) ..ccccccccceeeeeeeee- TR:

Vill

ee oo cave cceccabacncnccacnsceses eet 14

29 U.S.C. § 1132(a)....... AAO .10, 15

29 U.S.C. § 1132(a)(1)(B) | | 10, 13, 22

29 U.S.C. § 1132(a)(3).... eS ee

29 U.S.C. § 1132(e)(1).... 11, 12, 17,18

29 U.S.C. § 1144 (a).... visestedeus yee at

Other Authorities

The Division of Retirement Benefits Through

Qualified Domestic Relations Orders,

United States Department of Labor, Employee

Benefits Security Administration, available

http://www.dol.gov/ebsa/publications/qdros. ht

Statistical Abstract of the United States: 2006,

Table 72, U.S. Census Bureau, available

http://www.census.gov/prod/2005pubs/06statab

PE BI cic cuunsstssortsesavescs FA OO EE DRED 7

Statistical Abstract of the United States: 2008,

Table 57, U.S. Census Bureau, available

http://www.census.gov/compendia/statab/2010/

I nn cssccncpuavdnncs nies eed, 7

PETITION FOR WRIT OF CERTIORARI

Janis Carmona respectfully petitions for a writ

of certiorari to review the judgment of the United

States Court of Appeals for the Ninth Circuit in

this case.

OPINIONS BELOW

The amended opinion of the court of appeals is

reported at 603 F.3d 1041. Pet. App. la-43a. The

original opinion is reported at 544 F.3d 988. The

relevant opinions of the district court are

unreported but available at 2005 WL 6563968. Pet.

App. 44a-55a. The unpublished Nevada Supreme

Court opinion cited in these opinions can be found

at 2003 WL 25914267. Pet. App. 56a-64a. This

Court denied a petition for writ of certiorari to

review that unpublished Nevada opinion on April

19, 2004, which can be found at 541 U.S. 989.

STATEMENT OF JURISDICTION

The judgment of the court of appeals was stayed

on September 21, 2010. Pet. App. 68a-69a. A

petition for rehearing was denied on September 10,

2010. Pet. App. 65a-67a. The petition was timely

filed on June 16, 2010. The jurisdiction of this

Court rests on 28 U.S.C. § 1254(1).

STATUTORY AND REGULATORY

f PROVISIONS

Section 1257 of Title 28 of the United States

Code provides:

State courts; certiorari

(a) Final judgments or decrees rendered by the

highest court of a State in which a decision

could be had, may be reviewed by the

Supreme Court by writ of certiorari where

the validity of a treaty or statute of the

United States is drawn in question or where

the validity of a statute of any State is drawn

in question on the ground of its being

repugnant to the Constitution, treaties, or

laws of the United States, or where any title,

right, privilege, or immunity is specially set

up or claimed under the Constitution or the

treaties or statutes of, or any commission

held or authority exercised under, the United

States

(b) For the purposes of this section, the term

"highest court of a State" includes the

District of Columbia Court of Appeals.

reese e Reese es

Section 1331 of Title 28 of the United States

Code provides:

Federal question

The district courts shall have _ original

jurisdiction of al! civil actions arising under the

Constitution, laws, or treaties of the United

States.

Section 1441 of Title 28 of the United States

Code provides in pertinent part:

Actions removable generally

(a)

Except as otherwise expressly provided by

Act of Congress, any civil action brought in a

State court of which the district courts of the

United States have original jurisdiction, may

be removed by the defendant or the

defendants, to the district court of the United

States for the district and division embracing

the place where such action 1s pending. For

purposes of removal under this chapter [28

U.S.C. §§ 1441 et seq.], the citizenship of

defendants sued under fictitious names shall

be disregarded.

) Any civil action of which the district courts

have original jurisdiction founded on a claim

or right arising under the Constitution,

treaties or laws of the United States shall be

removable without regard to the citizenship

or residence of the parties. Any other such

action shall be removable only if none of the

parties in interest properly joined and served

as defendants is a citizen of the State in

which such action is brought. ...

Kee KeKe KEKE Kr KEK

Section 1446 of Title 28 of the United States

Code provides in pertinent part:

Procedure for removal

(b) The netice of removal of a civil action or

proceeding shall be filed within thirty days

after the receipt by the defendant, through

service or Otherwise, of a copy of the initial

pleading setting forth the claim for relief

upon which such action or proceeding is

based, or within thirty days after the service

of summons upon the defendant if such

initial pleading has then been filed in court

and is not required to be served on the

defendant, whichever period is shorter

Section 1132 of Title 29 of the United States

Code provides in pertinent part:

Civil enforcement

(a) Persons empowered to bring a civil action. A

civil action may be brought -

(1) by a participant or beneficiary

(A) for the relief provided for in

subsection (c) of this section, or

(B) to recover benefits due to him under

the terms of his plan, to enforce his rights

under the terms of the plan, or to clarify

his rights to future benefits under the

terms of the plan;

(3) by 2 participant, beneficiary, or fiduciary

(A) to enjoin any act or practice which

violates any provision of this subchapter

or the terms of the plan, or (B) to obtain

other appropriate equitable relief (i) to

redress such violations or (11) to enforce

any provisions of this subchapter or the

terms of the plan;

(e) Jurisdiction.

(1) Except for actions under subsection

(a)(1)(B) of this section, the district courts

of the United States shall have exclusive

jurisdiction of civil actions under this title

brought by the Secretary or by a

participant, beneficiary, fiduciary, or any

person referred to in section 101(f)(1) [29

U.S.C. § 1021()01)|. State courts of

competent jurisdiction and district courts

of the United States. shall have

concurrent jurisdiction of actions under

paragraphs (1)(3B) and (7) of subsection (a)

of this section.

Section 1144 of Title 29 of the United States

Code provides in pertinent part:

Other laws

(a) Supersedure; effective date. Except as

provided in subsection (b) of this section, the

provisions of this title and title IV shall

supersede any and all State laws insofar as

they may now or hereafter relate to any

employee benefit plan described in section

4(a) [29 U.S.C. § 1003(a)| and not exempt

under section 4(b) [29 U.S.C. § 1003(b)]. This

section shall take effect on January 1, 1975.

te KKK HK OK

STATEMENT OF CASE

More than 46 million private wage and salary

workers are currently covered by employer

provided retirement plans in the United States.? Of

those workers, roughly 38% over 17 million

Americans - distribute retirement benefits through

divorce proceedings.* Included in this statistic are

Lupe and Janis Carmona (nee Kester). Lupe

worked for the International Alliance of Theatrical

Stage Employees (IATSE) and the Hilton Hotel

Corporation (Hilton), and was eligible for pension

benefits from both employers. Pet. App. 57a. He

elected a qualified joint and survivor annuity

(QJSA) option for married couples from his

pensions, and listed Jants - his then current and

eighth wife as his survivor beneficiary. /bid.

Under the terms of these plans, Janis would receive

a portion of Lupe's monthly pension benefits upon

his death if she survived him. /d at 9a. Lupe retired

in 1992 and began drawing his pensions. But with

2 United States Department of Labor, Employee

Benefits Security Administration, The Division of Retirement

Benefits Through Qualified Domestic Relatuons Orders, at p.

1, available http://www.dol.gov/ebsa/publications/qdros. htm!

(last viewed December 6, 2010) C(QDRO manual’)

3 US. Census Bureau, Statistical Abstract of the

United States 2006, Table 72 available

http://www.census gov/prod/2005pubs/0G6statab/vitstat.pdf

(last viewed Dec. 2, 2010) (roughly 50% of marriages end in

divorce); U.S. Census Bureau, Statistical Abstract of the

United States: 2008, Table 57, available

http://www.census.gov/compendia/statab/20 10/tables/10s0057.

pdf (last viewed Dec. 2, 2010) (roughly 75% of individuals

married or divorced).

8

retirement came the unpleasant realization that

Janis and Lupe did not like each other, and Lupe

filed a complaint for divorce on October 27, 1994,

seeking, inter alia, his pension benefits from [ATSE

and Hilton. Pet. App. 70a-75a. Janis answered that

complaint on November 23, 1994, and counter-

claimed that she had a community property

interest in both pensions. Pet. App. 76a-85a.

Neither party included allegations that their rights

to benefits under the plans, or that their statutory

rights under ERISA, had been violated. /bid. Nor

did the couple name the [ATSE and Hilton plans,

their fiduciaries or their administrators as parties

to the divorce, or join them in later proceedings.

Ibid. Lupe was eventually awarded his pensions as

separate property, but ordered to pay Janis $1,500

for her marital portion. Pet. App. 57a.

Shortly after his divorce from Janis in 1997,

Lupe married Judy Carmona (nee Walkington) and

attempted to change the designation of his survivor

beneficiary from Janis to Judy. Ibid.

Representatives of both Hilton and = IATSE,

however, told Lupe that he could not change his

beneficiary after retiring. Jbid. The Hilton

representative added that ERISA prohibited such a

change unless a qualified domestic relations order

(QDRO), which “waives the spouse’s right to

survivor benefits [if] served on the Plan,” was

issued. Jbid. Lupe asked the Nevada family court to

enter a QDRQO _ ordering his' pension plan

administrators to grant his election of a new

survivor beneficiary. Jbid. At first, it refused. Pet.

App. 58a. But after Lupe's death, the family court

relented, finding that the parties had agreed that

Lupe's retirement benefits, including the survivor

7

benefits, were his sole and separate property. Pet.

App. 58a. The family court thus ordered the plan

administrators to change the survivor beneficiary

in accordance with Lupe's request, and if they did

not, the family court stated that it would “Order

the establishment of a Constructive Trust for the

benefit of Lupe's designated beneficiary wherein

the survivorship funds, if received by Janis, will be

held in trust for receipt by Lupe's designated

beneficiary.” Ibid. Because neither plan had

appeared in the divorce proceedings, Pet. App. 53a,

the family court eventually ordered Janis to

establish a constructive trust of the survivorship

funds from Lupe's-retirement plans for the benefit

of Judy. Pet. App. 58a.

Janis appealed to the Nevada Supreme Court,

claiming that ERISA, 1e., 29 U.S.C. § 1144(a),

preempted the family court's transfer of her

surviving spouse interest to Judy. Pet. App. 59a-

64a. Recognizing that both of Lupe's pensions were

regulated by ERISA, and admitting that the

interplay between ERISA and state law is not

always clear, the Nevada Supreme Court

nevertheless affirmed the judgment on the grounds

that neither the transfer nor the constructive trust

violated ERISA. Ibid. Specifically, the Nevada

Supreme Court held that Janis had waived her

interest by accepting $1,500 from Lupe and that a

constructive trust was a_ perfectly acceptable

instrument to transfer that interest. Pet. App. 60a

61. The Nevada Supreme Court also affirmed the

family court’s order that Janis pay Judy $15,000 in

attorney fees under state law, based on “the various

and extensive proceedings” surrounding her

opposition to that transfer. Pet. App. 64a. A petition

10)

to this Court met with a similar fate. Pet. App.

48a, citing 541 U.S. 989 (Janis’ petition for

certiorari denied).

While the appeal of her federal conflict

preemption defense was pending in the Nevada

Supreme Court, Janis filed a complaint in the

United States District Court for the District of

Nevada based on an unlawful denial of plan

benefits under 29 U.S.C. § 1132(a)(1)(B). Zbid. But

the district court dismissed that lawsuit under the

Rooker-Feldman doctrine on the grounds that

KRISA permitted state and federal courts to

exercise concurrent jurisdiction over ERISA

lawsuits for benefits, and the district court would

not “relitigate issues where another court had

jurisdiction and made a final determination.” Pet.

App. 48a. Janis then attempted to remove her

divorce proceedings to federal court — even though

neither she nor her ex-husband had alleged an

ERISA claim and the only federal issue was a

conflict preemption defense, (29 U.S.C. §§ 1132(a),

1144(a), respectively) — in an attempt to preserve

her rights under ERISA. Pet. App. 49a. But. she was

again rebuked by the district court, which found

that she had failed to timely remove her divorce

proceedings and, thus, had waived the right to

remove her ERISA claim. Jbid. Once again, the

district court cited to the Rooker-Feldman doctrine

and told Janis that a “United States District Court

does not have the authority to review a final

judgment” of a state court proceeding. bid.

1]

Undaunted, Janis filed a third federal lawsuit to

prevent the unlawful transfer of her surviving

spouse interest in the QJSA. Pet. App. 49a. This

time, however, she alleged that her statutory rights

under ERISA — not her right to benefits under the

terms of the plan — were violated and, thus, she

was entitled to equitable relief under 29 U.S.C. §

1132(a)(3). Jbid. Unlike her previous lawsuits, this

claim could not be prosecuted in state court, as

ERISA grants federal courts exclusive jurisdiction

over these matters. 29 U.S.C. § 1132(e)(1). Pet. App.

49a, 5la. Another distinction was that, for the first

time, Janis named the Hilton and IATSE plans and

fiduciaries as defendants (along with Judy). Having

finally appeared, the IATSE trustees filed a cross-

claim for declaratory relief against Judy averring

parallel ERISA allegations, viz., the Nevada family

court’s involuntary transfer of Janis’ surviving

spouse interest to Judy violated ERISA and was,

thus, preempted. Pet. App. 49a-50a. But, once

again, the district court refused to entertain Janis’

lawsuit because of the Rooker-Feldman doctrine.

et. App. 49a-52a.

Acknowledging that Rooker-Feldman did_ not

apply when Congress grants exclusive jurisdiction

to the federal courts, and that Congress granted

federal courts exclusive jurisdiction over ERISA

claims brought under 29 U.S.C. § 1132(a)(3), the

district court nevertheless dismissed Janis’ third

lawsuit for want of subject matter jurisdiction on

two grounds: First, no matter how artfully Janis

worded her complaint, she was still inviting the

district court to review and reject the Nevada

Supreme Court determinations, which the district

court could not do under this Court’s holding in

12

Exxon Mobil Corporation v. Saudi Basic Inds.

Corp., 544 U.S. 280, 284 (2005). Pet. App. 50a-51a.

Second, because the Nevada family court had

concurrent jurisdiction over her ERISA claim for

benefits, t.e., 29 U.S.C. § 1132(e)(1), Janis implicitly

subjected herself to the final determination of her

29 U.S.C. § 1132(a)(3) claim, and waived the right

to have her ERISA claim heard in federal court by

failing to remove her original divorce proceedings

before the thirty-day deadline expired under 28

U.S.C. § 1446(b). Pet. App. 5la-52a. And even

though it denied Judy’s motion to dismiss IATSE’s

cross-claim under the Rooker-Feldman doctrine on

the grounds that it (the plan) could not qualify as

“state court loser” because it was not a party to the

divorce proceedings, the district court eventually

concluded that the Nevada family court’s transfer

of Janis’ surviving spouse interest in the QJSA was

proper and, thus, dismissed that cross-claim on the

merits. Pet. App. 12a.

Both IATSE and Janis appealed to the Ninth

Circuit, which — in a strange turn of events

agreed that the Nevada family court had violated

ERISA by unlawfully transferring Janis’ surviving

spouse interest in the QJSA and, thus, ran afoul of

ERISA’s conflict preemption. Pet. App. 19a-42a.

But despite affirming IATSE’s cross-claim on the

merits, the court of appeals refused to reverse the

district court’s decline of subject matter jurisdiction

over Janis ERISA claim under the _ Rooker-

Feldman doctrine. Pet. App. 13a-19a. Specifically,

the Ninth Circuit agreed with the district court

that Rooker-Feldman was applicable because, like

Feldman, Janis did not argue that either Judy or

Hilton caused her injury. Pet. App. 16a, citing

13

District of Columbia Court of Appeals v. Feldman,

460 U.S. 462 (1983). Rather, Janis complained of a

“harm caused by a state court judgment that

directly withholds a benefit from [her] ... based on

an allegedly erroneous ruling by that court,” and

thus constituted an improper de facto appeal of a

state court judgment. Pet. App. 16a, quoting Noel v.

Hall, 341 F.3d 1148, 1163 (9th Cir. 2003). Finally,

the Ninth Circuit agreed with the district court

that, while her last lawsuit, as pleaded, arose

under the exclusive jurisdiction of federal courts,

when the parties proceeded initially, the state court

had concurrent jurisdiction to hear the ERISA

claim under 29 U.S.C. § 1132(a)(1)(B). Ibid. Since

Janis failed to remove those proceedings to federal

court, she implicitly subjected herself to the final

determination of the state court. Jbid. Because

Congress had established concurrent jurisdiction at

that time, the Ninth Circuit reasoned, it did not

intend to prevent the Rooker-Feldman

jurisdictional bar. /bid. “Although Janis may have

been right on the underlying substantive issue,” the

Ninth Circuit concluded, “she already had her day

in court on the question and, under the

circumstances, is barred under the _ Rooker-

Feldman doctrine from seeking recourse in federal

court at this time.” Pet. App. 42a.

It is from this tortured procedural history that

Janis has, once again, petitioned this Court for

certiorari.

14

SUMMARY OF ARGUMENT

There is a split in the Courts of Appeal over

whether the Rooker-Feldman doctrine prevents

United States District Courts from exercising

jurisdiction over cases brought by “state-court

losers” seeking federal court review of “state-court

judgments” on the grounds that Congress explicitly

granted exclusive jurisdiction of the subject matter

to federal courts.4 This split not only exists in

Bankruptcy appeals, it has now crept its way into

ERISA as the result of the decision handed down by

the Ninth Circuit in the instant action. The net

effect of that decision is to grant to state courts — by

way of a misapplication of the Rooker-Feldman

doctrine — the power to decide matters that fall

squarely within the exclusive purview of the federal

courts.

4 A similar circui:-split exists over the Anti-Injunction

Act, 28 U.S.C. § 2283, which prohibits district courts (with

certain exceptions) from “grant[ing] an injunction to stay

proceedings in a State court,” and whether that Act applies to

state court judgments that conflict with ERISA. See, e.g.,

General Motors Corp. v. Buha, 623 F.2d 455 (6th Cir. 1980),

citing Gilbert v. Burlington Industries, Inc., 765 F.2d 320, 329

(2nd Cir. 1985) (Anti-Injunction Act applies to state

judgments that conflict with ERISA); but see also Total Plan

Services v. Texas Retailers Association, 925 F.2d 142, 145, n.2

(5th Cir. 1991) (rejecting Buha). Accord, 1975 Salaried

Retirement Plan for Eligible Employees of Crucible, Inc. v.

Nobers, 968 F.2d 401 (3rd Cir. Pa. 1992) (recognizing conflict

between circuits without deciding).

15

The panel also created both an intra-circuit split

and an inter-circuit-split — and ran afoul of this

Court’s precedent — by hoiding that Janis could

remove her divorce proceedings to federal court.

Under the removal statute, a case filed in state

court may be removed to federal court when it

“arises under” federal law. Normally, a cause of

action is deemed to arise under federal law only

when issues of federal law appear on the face of the

plaintiffs complaint. Removal is not permitted if

federal law provides only a defense, even if the

defense is that state law is preempted under

conflict preemption or ordinary field preemption

analysis. Under the “complete preemption”

doctrine, however, a claim that is brought under

state law is properly viewed as federal in character

and thus removable to federal court if Congress has

created an exclusive federal cause of action that

occupies the field in which the plaintiffs claim

arises. This doctrine has been applied in the ERISA

context where a state court action that comes

within the scope of 29 U.S.C. § 1132(a) is re-

characterized as an action arising under federal

law for purposes of removal jurisdiction. The Ninth

Circuit, however, carved out an exception for

ERISA cases, requiring plan participants and

beneficiaries to remove their state court divorce

proceedings to federal court within thirty-days of

receiving the complaint or forever lose their right to

have a federal court decide a question Congress

intended be exclusive to the federal courts.

16

ARGUMENT

I. Despite this Court’s efforts, a Circuit-split

remains over whether the Rooker-Feldman

doctrine bars a “state court loser” from

collaterally attacking a_ state court

judgment in the United States District

Court, when Congress grants federal

courts exclusive jurisdiction over the

subject matter of that judgment.

The Rooker-Feldman doctrine recognizes that

federal district courts do not have subject matter

jurisdiction to hear appeals from state court

decisions. Exxon Mobil Corp. v. Saudi Basic Indus.

Corp., 544 U.S. 280, 284, (2005); Rooker v. Fidelity

Trust Co., 263 U.S. 4138, 414-16 (1923). Precisely

stated, the doctrine bars “cases brought by state

court losers complaining of injuries caused by state-

court judgments rendered before the district court

proceedings commenced and inviting district court

review and rejection of those judgments.” Exxon,

544 U.S. at 284. This jurisdictional bar is one of

congressional intent and not constitutional

mandate. Exxon, 544 U.S. at 291. The doctrine is

rooted both in 28 U.S.C. § 1257, which restricts the

federal judiciary's direct review of state court

judgments, and in notions of comity and federalism,

which presume that state courts are willing and

able to apply federal law and respect federal rights.

See Feldman, 460 U.S. at 483 n.16; Huffman uv.

Pursue, Ltd., 420 U.S. 592, 610-611 (1975). Despite

this Court’s recent efforts to clarify Rooker-

Feldman, see, e.g., Lance v. Dennis, 546 U.S. 459

(2006), Exxon, 544 U.S. at 284, a split remains in

the Courts of Appeal over whether that doctrine

bars a “state court loser” from collaterally attacking

a state court judgment in the United States District

Court, when Congress grants federal courts

exclusive jurisdiction over the subject matter of

that judgment.

There already exists a split in the circuits over

the question of bankruptcy courts reviewing state

court judgments. Compare, e.g., In re Gruntz, 202

F.3d 1074, 1079 (9th Cir. 2000) (en banc) (Circuits

accepting bankruptcy court exclusive jurisdiction to

review state court judgments under’ Rooker-

Feldman), and Jn re James, 940 F.2d 46, 52 (3rd

Cir. 1991); with, In re Ferren, 203 F.3d 559, 560

(8th Cir. 2000), and Singleton v. Fifth Third Bank

(In re Singleton), 230 B.R. 533 (B.A.P. 6th Cir.

1999). This split has now reached the shores of

ERISA. Under the Ninth Circuit’s holding in this

case, plan participants and beneficiaries lose the

right to have federal courts review state court

judgments — judgments which violate ERISA and

would otherwise be conflict- or field-preempted

despite a clear and unequivocal statement by

Congress that such claims be brought exclusively in

federal court. 29 U.S.C. §§ 1132(e)(1), 1144(a). Such

a decision not only runs afoul of Congressional

intent but also from this Court’s prior instruction,

which suggests that Rooker-Feldman provides no

protection from claims where Congress has

explicitly endowed federal courts with exclusive

jurisdiction. Verizon Md., Inc. v. Pub. Serv. Comm'n

of Md., 535 U.S. 635, 644, n.3, (2002) (noting that

“the Rooker-Feldman doctrine merely recognizes”

Congress’ choice of where to vest original

jurisdiction and appellate jurisdiction regarding

various matters); Exxon, 544 U.S. at 292, n.8&

13

(“Congress, if so minded, may explicitly empower

district courts to oversee certain. state-court

judgments and has done so, most notably, in

authorizing federal habeas review of state

prisoners petitions.”). Accord, Henrichs v. Valley

View Dev., 474 F.3d 609, 614 (9th Cir.), cert

denied, 552 U.S. 1037 (2007), citing Gruntz, 202

F.3d at 1079 (a state court judgment entered in a

case that falls within the federal courts’ exclusive

jurisdiction may be collaterally attacked in a

district court). Moreover, if Congress has the

authority to deny direct review of state court

judgments by United States District Courts under

28 U.S.C. § 1257, then the inference can be made,

and fairly so, that Congress must also have the

authority to grant sole and exclusive jurisdiction

over ERISA ciaims to those same district courts

under 28 U.S.C. § 1132(e)1). The Ninth Circuit

should not have presumed that a review of state

court judgments was inconsistent with the Rooker

Feldman doctrine, especially when those same

judgments clearly violate ERISA. In light of the

current circuit-split, Janis would ask the Court to

grant certiorari, and resolve this dispute once and

for all

19

Il. The Ninth Circuit created a circuit-split by

requiring ERISA participants and

beneficiaries to remove their garden-

variety divorce proceedings (within thirty-

days of receiving the complaint) to federal

court, regardless of whether the only

federal issue is a_ potential conflict

preemption defense, or lose the right to

proceed in federal court with any future

ERISA claim.

The Ninth Circuit also created a circuit-split by

carving-out an exception for plan participants and

beneficiaries initiating garden-variety divorce

proceedings in state court — Le., remove those

proceedings within thirty-days of receiving your

complaint, regardless of whether the only federal

issue is a potential conflict preemption defense — or

lose the right to proceed in federal court. This

exception runs afoul of the basic tenets regarding

removal from state to federal court. A civil action

filed in state court may only be removed to federal

court if the plaintiff's claim “aris[es] under” federal

law. 28 U.S.C. §§ 1331, 1441(a) and (b). An action

arises under federal law when a federal question

appears “on the face of the plaintiffs properly

pleaded complaint.” Caterpillar, Inc. v. Williams,

482 U.S. 386, 392 (1987); see Louisville & Nashville

R.R. v. Mottley, 211 U.S. 149, 152 (1908). A defense

is not part of a well-pleaded complaint; thus, when

federal preemption is only a defense, as is

ordinarily the case, preemption does not provide a

basis for removal. Aetna Health Inc. v. Davila, 542

U.S. 200, 207 (2004). That is so “even if the defense

is anticipated in the plaintiff's complaint, and even

if both parties admit that the defense is the only

20

question truly at issue in the case.” Rivet v. Regions

Bank, 522 U.S. 470, 475 (1988), quoting Franchise

Tax Bd. v. Construction Laborers Vacation Trust,

463 US. 1, 14 (1983). Ordinary preemption,

however pervasive or obvious, “does not transform

the plaintiff's state-law claims into federal claims

but rather extinguishes them altogether.” Rivet,

922 U.S. at 476.

An “independent corollary” to that rule is the

principle that “a plaintiff may not defeat removal

by omitting to plead necessary federal questions.”

Franchise Tax Bd., 463 U.S. at 22. Thus, “if a

federal cause of action completely preempts a state

cause of action any complaint that comes within

the scope of the federal cause of action necessarily

‘arises under’ federal law.” Jd. at 24. In those

circumstances, “a claim which comes within the

scope of that [federal] cause of action, even if

pleaded in terms of state law, is in reality based on

federal law.” Beneficial Nat'l Bank v. Anderson, 539

U.S. 1, 8 (2003).

The term “complete preemption” can_ be

misleading; it differs from ordinary, defensive

preemption not merely in degree, but in kind.

Complete preemption occurs when (1) Congress has

created an exclusive federal cause of action and, (2)

under the facts set out in the complaint, the

plaintiffs claim comes within the scope of that

cause of action. Beneficial Nat'l Bank, 539 U.S. at

8-9; see Franchise Tax Bd., 463 U.S. at 24;

Caterpillar, 482 U.S. at 388-399. That conclusion

follows from the plain language of the removal

statute. When federal law provides a cause of

action that occupies the field in which the plaintiff's

claim arises, the plaintiff's claim can arise only

under federal law. And, as described above, the

text of the removal statute clearly provides that

any action “arising under” federal law “shall be

removable” to federal court. 28 U.S.C. § 1441(b).

Consequently, a state-law claim “may not be

removed to federal court on the basis of a federal

defense, including the defense of pre-emption, even

if the defense is anticipated in the plaintiff's

complaint, and even if both parties concede that the

federal defense is the only question truly at issue.”

Caterpillar, 482 U.S. at 393.

The complete preemption rule advances the

purposes of the removal _ statute without

encroaching on the legitimate rights of plaintiffs or

offending principles of comity and _ federalism.

Federal question removal jurisdiction is designed

both to promote the accurate and uniform

interpretation of federal law by ensuring the

availability of a forum with special expertise in

that law and to protect the federal rights of

defendants. The complete preemption rule

advances those purposes because it ensures that

defendants retain access to the district courts to

litigate federal claims even when plaintiffs —

artfully or inadvertently — incorrectly characterize

those claims as arising under state law. At the

same time, the rule also respects the autonomy of

state courts. Removal is not permitted if federal

law provides only a defense — even if the defense is

that state law is preempted under conflict

preemption or ordinary field preemption analysis.

‘The complete preemption rule thus preserves both

state court primacy in resolving questions of state

law, and state court authority to determine in the

Fe

first instance whether state law must yield to

contrary federal law, while authorizing removal

when federal law actually provides the plaintiff's

cause of action. In that circumstance, removal is

entirely appropriate, because, in our federal

system, federal courts have primary responsibility

for resolving questions of federal law. The Ninth

Circuit's holding that Janis waived her right to

have her ERSIA claims heard in federal court

because she failed to timely remove her original

divorce proceedings runs. head-long into this

authority.

More importantly, none of the allegations in the

complaint and counter-claim initiating Janis and

Lupe’s divorce aver, much less suggest, that either

spouse was attempting to (1) redress violations of

ERISA's fiduciary provisions, (2) enjoin a practice

that violated ERISA, (3) obtain other cquitable

relief necessary to enforce ERISA or the terms of

the plan, (4) recover benefits due under the terms

of the plan, (5) enforce rights under the terms of a

plan, or (6) clarify rights to future benefits under

the terms of a plan. Nor were the IATSE and

Hilton plans or their fiduciaries named in those

divorce proceedings, further undercutting the

Ninth Circuit’s rationale. Cf, Yoon v. Fordham

Univ. Faculty & Admin. Ret. Plan, 263 F.3d 196,

207 (2nd Cir. 2001), citing 29 U.S.C. § 1132(a)(1)(B)

and quoting Leonelli v. Pennwalt Corp., 887 F.2d

1195, 1199 (2nd Cir. 1989) (“ERISA claims under

that section may be brought only against ‘the plan

and the plan administrators and trustees .. . in

their capacity as such . . .”). Phrased somewhat

differently, for more than thirteen years, Janis was

burdened with an ERISA lawsuit that she never

23

filed, based on an erroneous interpretation of

federal law that was sanctified by the Ninth

Circuit. The harm caused by that error casts a

shadow over the 17 million divorcing (or divorced)

American workers, who will now have to file their

divorce proceedings in, or remove those divorce

proceedings to, federal court; or lose the right to

(exclusive) federal court jurisdiction over any

potential ERISA claim. Such an error cannot be left

to stand.

CONCLUSION

or the foregoing reasons, this Court should

grant this petition for certiorari, reverse the

judgment of the court of appeals, and remand this

back to the Ninth Circuit for further proceedings.

Scottlynn J Hubbard TV

Counsel of Record

Law Offices of Lynn Hubbard

12 Williamsburg Lane

Chico, California 95926

(530) 895-3252

lawofchaos@aol.com

Counsel for Petitioner

December 9, 2010

APPENDIX

Appendix A:

Appendix B:

Appendix C:

Appendix D:

Appendix E:

Appendix F:

Appendix G:

APPENDIX

Ninth Circuit Amended Opinion,

atoms Rime 6, DOG avis ceceneancans la

District Court Memorandum,

dated September 30, 2005....... ... 44a

Nevada Supreme Court Order,

dated October 21, 2009 ................ o6a

Ninth Circuit Order re Rehearing,

date September 10, 2010............. 65a

Ninth Circuit Order Staying

Mandate,

dated September 21, 2010............ 68a

Lupe Complaint for Divorce,

dated October 27, 1994 ............. .. 10a

Janis Answer to Complaint

and Counter-claim.,

dated November 23. 1994............ 76a

APPENDIX A

UNITED STATES COURT OF APPEALS

FOR THE NINTH CIRCUIT

Nos. 06-15581, 06-15938

JANIS CARMONA,

Plaintiff,

JUDY CARMONA: HILTON HOTELS CORPORATION,

RETIREMENT PLAN,

Defendants, |

V.

NEVADA RESORT ASSOCIATION INTERNATIONAL

ALLIANCE OF THEATRICAL AND STATE EMPLOYEES

LOCAL 720 PENSION TRUST (1.A.T.S.E. TRUSTEES),

Cross-Claimant-Appellant,

JUDY CARMONA, SUCCESSOR REPRESENTATIVE OF

LUPE N. CARMONA DECEASED,

Cross-Defendant-Appellee.

2a

JANIS CARMONA, A.K.A. JANIS KESTER, |

Plaintiff-Appellant,

V.

JUDY CARMONA, SUCCESSOR REPRESENTATIVE OF

LUPE N. CARMONA DECEASED; HILTON HOTELS

CORPORATION, RETIREMENT PLAN

Defendants-Appellees.

ORDER AMENDING OPINION AND

DENYING REHEARING AND AMENDED

OPINION

Appeal from the United States District Court

for the District of Nevada

Kent J. Dawson, District Judge, Presiding

Argued and Submitted

March 11, 2008

Filed Sept. 17, 2008

Amended May 4, 2010

Before: Hawkins, Thomas, and Clifton,

Circuit Judges

Opinion by Judge Clifton

3a

ORDER

This court's opinion, filed September 17, 2008, is

amended as follows:

I. At pages 138098 (2 times), 13099, 13102,

13113 (3 times including 2 times within note 13) of

the slip opinion (544 F.3d at 998 (2 times), 1000,

1007 (3 times including 2 times within note 13)),

replace <anti-alienation> with < antialienation >

(without hyphen) to conform to the usage in

Kennedy v. Plan Administrator for DuPont Savings

& Investment Plan, --- U.S. ----, 129 S.Ct. 865, 172

L.Ed.2d 662 (2009).

2. On page 13090 of the slip opinion (544 F.3d at

993), replace <the Nevada family court, perhaps

without taking into account the nature of the QJSA

Survivor annuities, granted> with <the Nevada

family court, perhaps without taking into account

either the nature of the QJSA survivor annuities or

the terms of the plans, granted>.

3. On page 13097 of the slip opinion (544 F.3d at

998), following <ERISA pension plans must comply

with participation, vesting, and = funding

requirements. /d.> add:

<The statute also established “a

straightforward rule of hewing to the

directives of the plan documents,” imposing

on plan administrators a “bright-line

requirement to follow plan documents in

distributing benefits.” Kennedy v. Plan

Administrator for DuPont Savings &

4a

Investment Plan, ---U.S. ----, 129 S.Ct. 865,

’

875, 876, 172 L.Ed.2d 662 (2009).>

4. Move the following language appearing on

page 13100 of the slip opinion (544 F.3d at 999) to

page 13099 of the slip opinion (544 F.3d at 998),

between and qualified>:

<A valid DRO can be any judgment, decree,

or order which (1) “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 (2) “is made pursuant to a State

domestic relations law.” 29 U.S.C. §

1056(d)(3)(B)(ai).>

5. On page 13099 of the slip opinion (544 F.3d at

998), following Hamilton, 433 F.3d at 1096 (citing

29 U.S.C. § 1056(d)(3)(B)G)(D) Gnternal quotation

marks omitted).>, add a new footnote 6 (and

renumber subsequent footnotes):

To be sure, a party can waive an entitlement

to an interest without expressing that waiver

in the form of a QDRO, as the Supreme

Court recently held. Although the Fifth

Circuit had held a waiver by a divorcing

spouse expressed in a _ divorce decree

ineffective under ERISA's antialienation

provision because it was not expressed in a

QDRO, the Court held that such a waiver of

rights could be effective nonetheless.

Kennedy, 129 S.Ct. at 870-74. That ability to

alter the entitlement to benefits outside of a

QDRO is lmited to a waiver of rights,

however. It does not permit an assignment of

interest to anyone else or an identification of

an alternate payee; that still requires a

QDRO to be effective under ERISA. Id. at

873.

6. On page 13100 of the slip opinion (544 F.3d at

1000), replace <Because Janis was Lupe's spouse at

the time of his retirement, her remainder interests

vested at the time of his retirement and no QDRO

can reassign the benefits.> with <Because Janis

was Lupe's spouse at the time of his retirement,

IATSE argues that her remainder interests vested

at the time of his retirement and no QDRO can

reassign the benefits.>

7. On page 13107 of the slip opinion (544 F.3d at

1003), in the citation to McGowan v. NJR Serv.

Corp. replace with <(omitted), abrogated on other

grounds by Kennedy, --- U.S. ----, 129 S.Ct. 865, 172

L.Ed.2d 662.>.

8. On pages 13110-11 of the slip opinion (544

F.3d at 1005-06), replace the five paragraphs that

begin with also argues that Janis waived her right>

and end before the heading C. The Constructive

Trust> with the following two paragraphs:

Judy also argues that Janis waived her right

to the surviving spouse benefits by the

property settlement when the state court

entered its divorce decree. As the Supreme

Court made clear in Kennedy, ERISA's

antialienation provision does not prohibit a

surviving spouse beneficiary from waiving

his or her interest in plan benefits, but such

ba

a waiver must also conform to. plan

procedures and instruments. Indeed, the

Court concluded that the plan administrator

in that case was not, under the terms of the

plan, required to honor the waiver of benefits

contained in the divorce decree and that the

continued payment of benefits to the prior

spouse was proper. See Kennedy, 129 S.Ct. at

874-78. Under the so-called “plan documents

rule,” plan administrators must “hew[ ] to

the directives of the plan documents” rather

than “examin[ing] a multitude of external

documents that might purport to affect the

dispensation of benefits” and becoming

“drawn into litigation like this over the

meaning and enforceability of purported

waivers. Id. at 876, 877 (internal quotation

marks omitted).

Both the IATSE plan documents and

KRISA's statutory scheme allow for the

waiver of surviving spouse benefits with both

spouses’ written consent during the benefits

election period prior to the participant's

retirement. 29 U.S.C. § 1055(c)(3). That

procedure was not followed here. Judy has

identified nothing in the IATSE plan

documents which” require’ the _ plan

administrator to redirect surviving spouse

benefits to Judy, who was not, at the time of

retirement and vesting, either a present or

former spouse. Even if it is assumed that

Janis had the authority to disclaim benefits,

there is nothing that provides for them to be

assigned instead to Judy.

9. On page 13114 of the slip opinion (544 F.3d at

1007), following the sentence <It may not be that

all constructive trusts instituted by state courts,

particularly those that seek to recover ill-gotten

gains, will have a sufficient connection with or

reference to an ERISA plan to trigger ERISA's

preemption provision.>, add a new footnote 15

In Kennedy, the Court explicitly declined

to express a view on whether an action could

have been brought to obtain benefits from

the fermer spouse after they had been

distributed to her. 129 S.Ct. at 875 n. 10

The opinion, as amended, will thus appear a

attached

With the opinion as amended, the petition for

rehearing en banc, filed October 2, 2008, 1:

DENIED. If any party wishes to file a new petition

for rehearing and/or petition for rehearing en banc,

it may do so within 14 days from the date of thi:

order

OPINION

CLIFTON, Circuit Judge

This case requires us to once again navigate the

complex statutory scheme set out in the Employee

Retirement Income Security Act of 1974 (“ERISA”),

88 Stat. 832, as amended, 29 U.S.C. § 1001 et seq.,

and to answer an open question in this Circuit:

whether or not a participant to an ERISA regulated

Qualified Joint and Survivor Annuity (“QJSA”)

plan may change the surviving spouse beneficiary

Sa

after the participant has retired and the annuity

has become payable.

The conflict here arises between the final two

wives of Lupe Carmona, a participant in two

ERISA regulated pension plans, the Hilton Hotels

Pension Plan (“Hilton”) and the Nevada Resort

Association International Alliance of Theatrical

Stage Employees Local Pension Trust (IATSE”).

Janis Carmona, Lupe's eighth wife and his spouse

at the time of his retirement, appeals the district

court's dismissal of her complaint for lack of

jurisdiction against Hilton and Judy Carmona,

Lupe's ninth wife and his spouse at the time of his

death.! IA‘SE, Lupe's’ second pension plan

provider, appeals the district court's grant of

summary judgment in favor of Judy on its cross-

claim. On the merits, both IATSE and Janis argue

that Janis, as Lupe's spouse at the time of his

retirement, is the nrightful surviving § spouse

beneficiary for the purposes of Lupe's retirement

plan because her interest in surviving spouse

benefits irrevocably vested at the time of Lupe's

retirement.

Joining the Fourth Circuit, as well as a number

of other jurisdictions, we hold that QJSA surviving

spouse benefits irrevocably vest in the participant's

spouse at the time of the annuity start date — in

1 Because they share the same last name, in this

opinion we refer to Lupe, Janis, and Judy by their first

names.

Ya

this case the participant's retirement? — and may

not be reassigned to a subsequent spouse. Applying

that conclusion to the judgment entered by the

district court in this case, we affirm in part and

reverse in part.

I. Background

The essential facts of this case are undisputed.

Lupe Carmona married his eighth wife,? Janis

Carmona (nee Kester), in 1988. While they were

married, Lupe designated Janis as his survivor

beneficiary under two pension plans” which

provided QJSA benefits, Hilton and IATSE. Under

the terms of these plans, Janis would receive a

portion of Lupe's monthly pension benefits upon his

death if she survived him. After naming Janis as

the survivor beneficiary of both plans, Lupe retired

and began collecting pension benefits under the

“Annuity start date” and “retirement date” are the

same date in this case and we use the two. terms

synonymously. For the purposes of QJSA_ benefits, the

retirement date and the annuity start date are often the

same. As a result, most of the cases addressing this issue

have also used “retirement date” synonymously with “annuity

start date.” We recognize that the terms may not always be

synonymous: for example, a participant could retire early, but

he or she may not receive benefit payments until a later date

For the purposes of this opinion, however, we need not

determine what effect an early retirement would have on the

vesting rules. We leave to another day whether the same

vesting ruies apply to a participant's early retirement

3 Although Lupe had many wives, the dispute in this

case only concerns wives number eight and nine. None of the

previous seven wives are involved in the present litigation.

LOa

plans in 1992. Then, in 1994, Lupe and Janis began

divorce proceedings.

Prior to entry of the formal divorce decree, Lupe

inquired into whether he could remove Janis as the

named survivor beneficiary. The two plan

administrators each refused to change’ the

designated survivor spouse’ beneficiary and

indicated that the designation was irrevocable upon

Lupe's retirement. Nonetheless, in its 1997 divorce

decree, the Nevada family court, perhaps without

taking into account either the nature of the QJSA

survivor annuities or the terms of the plans,

granted Lupe both the IATSE and Hilton pensions

as his sole and separate property. The family court

awarded Janis her own pension plan as her sole

and separate property as well. Because there was a

difference between the value of the pension

awarded to Janis and the value of the pensions

awarded to Lupe, the court also ordered that Lupe

pay Janis $1500 “as and for an equalization of the

values of the marital portion of the pensions

divided.”

In 1997, after his divorce from Janis had been

finahzed, Lupe married Judy Carmona (nee

Walkington), his ninth and final spouse. He

petitioned the family court for a Qualified Domestic

Relations Order (“QDRO”) revoking Janis's

designation as the survivor beneficiary of the

IATSE and Hilton pensions and substituting Judy,

his new wife. Lupe died in 1999. Judy survived

him, as did Janis. The day after Lupe's death, the

family court concluded that Janis had waived her

right to Lupe's pension plan benefits by the divorce

decree's allocation of property and that Janis would

lla

be unjustly enriched if she remained the survivor

beneficiary. To avoid an inequitable result, the

court ordered the plan administrators to change the

survivor beneficiary from Janis to Judy.

Alternatively, if the plans refused or were unable to

change the beneficiary, the family court ordered the

funds Janis received to be placed in a constructive

trust with Judy as the beneficiary.

Janis appealed the family court's decision to the

Nevada Supreme Court. In 2003, that court

affirmed the family court order and concluded that

ERISA did not preempt either the family court's

order to change the beneficiaries or the constructive

trust placed on the plan proceeds.4 Janis sought

review of the decision by the United States

Supreme Court, but the Court denied certiorari.

Also during this’ time, Janis’~ declared

bankruptcy. The bankruptcy court also concluded

that Janis did not have a legal or equitable interest

in the survivor benefits from the two QJSAs.

4 While Janis was pursuing her original appeal through

the Nevada system, she also brought suit in Nevada federal

district court seeking to recover benefits under the terms of

the ERISA pension plan. See 29 U.S.C. § 1132(a)(1)(B). Janis

named the family court judge, Judy's attorneys, the Hilton

Plan administrators and Judy in the suit. In 2001, before the

Nevada Supreme Court made its final determination in the

original case, District Judge Philip M. Pro dismissed the suit

against all the defendants except for Hilton, concluding that

the court lacked subject matter jurisdiction under the Rooker-

Feldman doctrine. The district court later dismissed Hilton

because Janis could not join Judy, an indispensable party.

12a

In 2004, after the Nevada Supreme Court

decision, the family court issued another order

requiring Janis to deposit the survivor benefit

funds into a constructive trust. At the same time,

the family court also entered two orders, each

labeled as a “Qualified Domestic Relations Order,”

directing the two plans to pay survivor benefits

either to Judy or to the constructive trust. Janis

attempted to remove the case to federal court but

the federal district court remanded the action back

to the family court, concluding that Janis had failed

to timely file for removal and, in any event, that

the Rooker-Feldman doctrine required the court to

dismiss the suit for lack of jurisdiction.

This appeal originates from the most recent

federal suit filed by Janis against Judy, Hilton, and

IATSE. Janis brought suit under 29 U.S.C. §

1132(a)(3) seeking “to enjoin any act or practice

which violates any provision [of ERISA] or the

terms of the plan.” In response to Janis's suit,

[ATSE Trustees filed a cross-claim against Judy

seeking declaratory relief.

The district court concluded that the Rooker-

Feldman doctrine barred Janis's suit against Judy

and Hilton. The court also concluded that neither

Rooker-Feldman nor res judicata barred IATSE's

claim because it was not a party to the prior suits

and was not in privity with Janis. On the merits,

the district court concluded that ERISA does not

preclude a state court from issuing a QDRO

substituting an alternate payee for a surviving

spouse after a plan participant's retirement. IATSE

appeals the district court's denial of summary

judgment and subsequent dismissal of its

l3a

complaint against Judy. Janis appeals the district

court's decision that it lacked subject matter

jurisdiction over Janis's claims against Hilton and

Judy. We consider both appeals together because

they arise from the same factual background.

II. Discussion

We review an application of the fRooker-

Feldman doctrine de novo. Noel v. Hall, 341 F.3d

1148, 1154 (9th Cir.2003). The interpretation of

ERISA, including whether ERISA preempts state

law, is a question of law which we also review de

novo. Metropolitan Life Ins. Co. v. Parker, 436 F.3d

1109, 1113 (9th Cir.2006); Cleghorn v. Blue Shield

of California, 408 F.3d 1222, 1225 (9th Cir.2005).

A. The Rooker-Feldman Doctrine and Preclusion

We first consider whether any preclusion

doctrine prevents Janis from bringing her claims

against Judy and Hilton, or IATSE from bringing

its declaratory judgment action. We agree with the

district court and conclude that the district court

lacked jurisdiction, under the fFooker-Keldman

doctrine, to adjudicate Janis's claims against Judy

and Hilton, but that IATSE is not precluded from

asserting its cross-claim here.

The Rooker-Feldman doctrine takes its name

from two Supreme Court cases: Rooker v. Fidelity

Trust Co., 263 U.S. 413, 44 S.Ct. 149, 68 L.Ed. 362

(1923), and District of Columbia Court of Appeals v.

Feldman, 460 U.S. 462, 103 S.Ct. 1303, 75 L.Ed.2d

206 (1983). It stands for the © relatively

straightforward principle that federal district

14a

courts do not have jurisdiction to hear de facto

appeals from state court judgments. Noel, 341 F.3d

at 1155. The jurisdictional prohibition arises from a

negative inference drawn from 28 U.S.C. § 1257

which grants jurisdiction to review state court

decisions in the United States Supreme Court.

Kougasian v. TMSL, Inc., 359 F.3d 1136, 1139 (9th

Cir.2004) (citation omitted). Because it grants

jurisdiction to the Supreme Court, section 1257

impliedly prohibits lower federal courts from

reviewing state court decisions. /d.

[1] Stated simply, the Rooker-Feldman doctrine

bars suits “brought by state-court losers

complaining of injuries caused by state-court

judgments rendered before the district court

proceedings commenced and inviting district court

review and rejection of those judgments.” Exxon

Mobil Corp. v. Saudi Basic Indust. Corp., 544 U.S.

280, 284, 125 S.Ct. 1517, 161 L.Ed.2d 454 (2005).

In practice, the Rooker-Feldman doctrine is a fairly

narrow preclusion doctrine, separate and distinct

from res judicata and collateral estoppel. See Noel,

341 F.3d at 1162-64.

We have previously explained how federal

courts should distinguish a forbidden de facto

appeal of a state court decision that is barred by

Rooker-Feldman from a suit that is barred by other

preclusion principles. A suit brought in federal

district court is a “de facto appeal” forbidden by

Rooker-Feldman when “a federal plaintiff asserts

as a legal wrong an allegedly erroneous decision by

a state court, and seeks relief from a state court

judgment based on that decision.” Jd. at 1164. In

contrast, if a plaintiff “asserts as a legal wrong an

lda

allegedly illegal act or omission by an adverse

party, Rooker-Feldman does not bar jurisdiction.”

Id.

[2] Although it is often misapplied, we agree

with the district court that Rooker-Feldman is

applicable in this case, and therefore the district

court was correct in dismissing Janis's claims for

lack of jurisdiction. According to her amended

complaint, Janis claimed that the family court

orders were based upon an erroneous application of

KRISA preemption law and that the family court

unlawfully reassigned benefits in which she had an

irrevocable vested interest. She sought relief from

the state court orders and prayed for the federal

district court to “order that the proceedings in

Family Court in case number D181580_ be

dismissed with prejudice” and to enjoin

enforcement of the orders. Thus she was asserting

both that her injury was caused by a “legal error or

errors by the state court” and that the appropriate

remedy was “relief from the state court judgment.”

Kougasian, 359 F.3d at 1140.

The types of claims Janis presented in this case

parallel those asserted in Feldman, 460 U.S. 462,

103 S.Ct. 1303, 75 L.Ed.2d 206, one of the cases

from which the doctrine takes its name. In

Feldman, the federal plaintiffs sought admission to

the District of Columbia bar. The local court

refused to grant the plaintiffs waivers from the

local rule that only graduates from accredited law

schools could sit for the bar exam. The plaintiffs

then filed suit in federal court. The plaintiffs

sought declaratory judgments that the rule violated

the Fifth Amendment, and injunctions that would

l6a

require the defendants to permit them to take the

examination. One of the plaintifis also sought the

alternative relief of admission to the bar or a

determination of whether his training provided him

the same competence as graduates of accredited

law schools. See Feldman, 460 U.S. at 468-69, 103

S.Ct. 1303. Th» appeals were consolidated and the

Supreme Court held that the suit was a de facto

appeal of the local court order to the extent that it

sought review of the local court's denial of waiver.

As such the district court lacked subject matter

jurisdiction to hear the appeal. Jd. at 482, 103 S.Ct.

1303.

[3] Like Feldman, Janis did not argue that

either Judy or Hilton caused her injury, claims that

would not be within the limits of Rooker-Feldman.

See Noel, 341 F.3d at 1163. Rather, Janis

complained of a “harm caused by a state court

judgment that directly withholds a_ benefit

from{her] ... based on an allegedly erroneous ruling

by that court.” Jd. Her claim therefore fits within

the narrow constraints of the Ninth Circuit's

application of the Rooker-Feldman doctrine. We

agree with the district court that it lacked

jurisdiction to hear the merits of Janis's claims

against Hilton and Judy because Janis's suit was a

forbidden de facto appeal of a state court judgment.

[4] Janis also argues that Rooker-Feldman does

not apply to state court orders that conflict with

ERISA because ERISA grants exclusive jurisdiction

to the federal courts. Rooker-Feldman's

jurisdictional bar is one of congressional intent and

not constitutional mandate. Mozes v. Mozes, 239

F.3d 1067, 1085 n. 55 (9th Cir.2001). Where

l7a

Congress explicitly grants exclusive jurisdiction to

federal courts, Rooker-Feldman cannot’ bar

collateral review of a state court order in federal

court. See In re Gruntz, 202 F.3d 1074, 1078-79 (9th

Cir.2000) (en banc) (establishing that collateral

review of state court proceedings in habeas and

bankruptcy cases is not jurisdictionally barred

under Rooker-Feldman ); see also Mozes, 239 F.3d

at 1085 n. 55; G.C. and K.B. Inv., Inc. v. Wilson,

326 F.3d 1096, 1103 n. 4 (9th Cir.2003).

[5] Although the present suit, as pleaded, arises

under the exclusive jurisdiction of federal courts,

when the parties proceeded initially, the state court

had concurrent jurisdiction to hear the ERISA

claim under 29 U.S.C. § 1132(a)(1)(B). In the state

court proceedings, Janis failed to remove the

proceedings to federal court and thus implicitly

subjected herself to the final determination of the

state court. Because Congress had established

concurrent jurisdiction at that time, we conclude

that it did not intend to prevent the Rooker-

Feldman jurisdictional bar.

[6] Although Janis’s claims are barred, IATSE's

cross claim against Judy is not, even though it

raises the same legal issue. Neither the law of the

case doctrine nor state law res judicata principles

bar IATSE's cross claim. The law of the case

doctrine only applies to successive appeals in the

same suit. See Hsu v. County of Clark, 123 Nev.

625, 173 P.3d 724, 730 n. 26 (2007). Where the suit

involves a new party and new claims, as it does

here, it 1s only res judicata, and not the law of the

case doctrine, that may apply. See id.

l8a

[7] Similarly, res judicata does not preclude

IATSE from establishing its obligations with

respect to Judy and Janis. Under Nevada law, the

party asserting res judicata must establish (1) the

identical issue was already decided, (2) there was a

final judgment on the merits, and (3) the suit

involved the same party or their privies. See

Holcombe v. Hosmer, 477 F.3d 1094, 1097-98 (9th

Cir.2007); Bennett v. Fid. & Deposit Co. of Md., 98

Nev. 449, 652 P.2d 1178, 1180 (1982). Res judicata

does not apply here because IATSE was not a party

to the first state court suit nor was it in privity

with Janis. Although they advance _ similar

arguments with a similar goal in mind-to establish

that Lupe was precluded from changing Janis's

beneficiary status after his retirement-they each

maintain unique interests. IATSE must concern

itself with the correct administration of its pension

plans, and it has fiduciary duties distinct from the

interests of the wives in this case. See, e.g., 29

U.S.C. § 1104. Janis's interest is merely in

receiving the remainder benefits to which she feels

she is entitled. Because Janis and IATSE do not

share an identity of interests, Janis's prior suits

have no preclusive effect on IATSE's claim that the

state court QDROs were insufficient to transfer

benefits.5 See Taylor v. Sturgell, 553 U.S. 880, 128

5 In addition to illustrating the pitfails of interpreting

ERISA, this case also illustrates the problems that arise when

a plan trustee fails to join litigation until the eleventh hour

despite the plan's ongoing interest in the outcome. Although

we conclude that no legal doctrine prohibits [ATSE from

bringing the’ present declaratory judgment action, we agree

with the district court that the plan trustee's failure to join

itself to the litigation earlier was unnecessary and could have

19a

S.Ct. 2161, 171 L.Ed.2d 155 (2008) (overruling

Kourtis vu. Cameron, 419 F.3d 989, 998 (9th

Cir.2005) and narrowly construing circumstances

in which a non-party may be bound by prior

judgment); LaForge v. State, Univ. and Cmty.

College Sys. of Nev., 116 Nev. 415, 997 P.2d 130,

133 (2000). We turn now to the merits of the case,

and the heart of the ERISA question.

B. The Effect of a Domestic Relations Order on

Survivor Benefits

Congress originally enacted ERISA to protect

the rights of workers who earn pension benefits

and to encourage plan participation. PAUL J.

SCHNEIDER, BRIAN M. PINHEIRO, ERISA: A

COMPREHENSIVE GUIDE § 1.02 (3d ed.2008). In

addition to protecting plan participants, Congress

also sought to protect plan beneficiaries. See Boggs

v. Boggs, 520 U.S. 833, 845, 117 S.Ct. 1754, 138

L.Ed.2d 45 (1997). In order to meet those ends

Congress enacted an intricate, comprehensive

statute that governs both pension and welfare

plans. /d. at 841, 117 S.Ct. 1754. ERISA pension

plans must comply with participation, vesting, and

funding requirements. /d. The’ statute also

established “a straightforward rule of hewing to the

spared the parties involved great time and expense. We also

note that while the result here may seem anomalous-IATSE

may pay out benefits to Janis while Hilton may pay out

benefits to Judy-we conclude that this is the result dictated by

the unusual circumstances before us. The application of

preclusion doctrines and jurisdictional bars cannot turn on

the outcome of the underlying arguments on the merits

2VUa

directives of the plan documents,” imposing on plan

administrators a “bright-line requirement to follow

plan documents in distributing benefits.” Kennedy

v. Plan Administrator for DuPont Savings &

Investment Plan, --- U.S. ----, 129 S.Ct. 865, 875

876, 172 L.Ed.2d 662 (2009).

More recently, Congress further refined the

statutory framework with the Retirement Equity

Act of 1984 (“REA”), Pub.L. No. 98-397, 98 Stat.

1426, which particularly sought to protect the

rights of surviving spouses. These amendments

modified and strengthened the expansive coverage

for surviving spouses by providing economic

security through “a stream of income to surviving

spouses,” even after the participant's death. Boggs,

520 U.S. at 843, 117 S.Ct. 1754

In order to protect surviving spouses in the

event of the plan participant's death or divorce,

ERISA provides for two types of survivor annuity

benefits. See Hamilton v. Wash. State Plumbing &

Pipefitting Indus. Pension Plan, 433 F.3d 1091,

1095 (9th Cir.2006). If a vested participant dies

before the annuity start date and the participant is

survived by a spouse, the surviving spouse is

entitled to a qualified preretirement survivor

annuity (“QPSA”). 29 U.S.C. § 1055(a)(2). Because

Lupe died after retirement, his annuity benefits

were paid in the form of the second type, a qualified

joint and survivor annuity or “QJSA.” 29 U.S.C. §

1055(a)(1). QJSA benefits arise when the

participant does not die before the annuity starting

date. Id. These benefits are payable to the plan

participant for his lifetime after the annuity start

date and, if the plan participant dies before his

spouse, the surviving spouse will receive no les

than 50 percent of the amount of the annuity for

the remainder of her lfetime. See 29 U.S.C. §

1055(d)(1)(A).

[8] “ERISA requires that every[QJSA] include

an annuity payable to a nonparticipant surviving

spouse. Boggs, 520 U.S. at 842, 117 S.Ct. 1754

These QJSA benefits are particular to the surviving

spouse and may not be waived by the participant

alone. /d. In order for a participant's spouse to

waive her interests in QJSA benefits, the spouse

must consent in writing, and in the presence of a

plan representative or notary public, during the

applicable election period. See 29 U.S.C. § 1055(c)

Under these provisions, Janis, as Lupe's surviving

spouse at the time of his retirement, was entitled to

his QJSA benefits after his death. She did not

waive her interest in the surviving spouse benefit:

during the applicable election period or consent to

have Judy designated as the beneficiary. See Boggs,

520 U.S. at 842, 117 S.Ct. 1754. We must

determine, then, whether other provisions of

ERISA permit the Nevada family court to reassign

the QJSA survivor benefits from Janis to Judy

ERISA contains an antialienation provision and

a preemption provision that restrict the ability of

state courts and plan participants to transfer and

alter interests in ERISA-governed retirement

benefits. See 29 U.S.C. § 1056(d)(1) (Each pension

plan shall provide that benefits provided under the

plan may not be assigned or alienated.”); 29 U.S.C

§ 1144(a) (establishing that ERISA “supercede[s]

any and all State laws insofar as they may ... relate

to any employee benefit plan ). Despite this

broad preemption and antialienation scheme,

Congress has recognized that states, in some

circumstances, should be able to enforce their own

domestic relations laws with respect to ERISA

pensions. As a result, state domestic relations

orders (“DROs”) that comply with = statutory

requirements are exempt from both the

antialienation and preemption. provisions of

ERISA. 29 U.S.C. § 1144(b)(7); 29 U.S.C. §

1056(d)(3); Hamilton, 433 F.3d at 1096 n.5. A valid

DRO can be any judgment, decree, or order which

(1) “relates to the provision of child support,

alimony payments, or marital property rights to a

spouse, former spouse, child, or other dependant of

a participant,” and (2) “is made pursuant to a State

domestic relations law.” 29 US.C. §

1056(d)(3)(B)(i). The qualfied domestic relations

order, or QDRO, “is a subset of domestic relations

orders that recognizes the right of an alternate

payee to receive all or a portion of the benefits

payable with respect to a participant under the

pian.” Hamilton, 433 F.3d at 1096 (citing 29 U.S.C.

§ 1056(d)(3)(B)G)(D) Gnternal quotation marks

omitted).®

6 To be sure, a party can waive an entitlement to an

interest without expressing that waiver in the form of a

QDRO, as the Supreme Court recently held. Although the

Fifth Circuit had held a waiver by a divorcing spouse

expressed in a divorce decree ineffective under ERISA's

antialhenation provision because it was not expressed in a

QDRO, the Court held that such a waiver of rights could be

effective nonetheless. Kennedy, 129 S.Ct. at 870-74. That

ability to alter the entitlement to benefits out-side of a QDRO

is limited to a waiver of rights, however. It does not permit an

Although state courts, via DROs, may create

enforceable interests in the proceeds of an ERISA

plan, there are limitations on the ability of state

courts to create enforceable property interests in

alternate payees. See Trs. of the Dirs. Guild of Am.-

Producer Pension Benefits Plans v. Tise, 234 F.3d

415, 420 (9th Cir.2000). First, in order for a DRO to

be considered a QDRO, the state courts must fulfill

certain specificity requirements. These

requirements allow a plan administrator to more

easily administer the plan and reduce the risk of

making improper payments. See Hamilton, 433

F.3d at 1096-97 (citing In re Gendreau, 122 F.3d

815, 817-18 (9th Cir.1997)). A DRO meets the

requirements of a QDRO and thus is enforceable

only if the order “clearly specifies” (1) the name and

mailing address of both the participant and the

alternate payees, (2) the amount or percentage of

the participant's benefits to be paid to each

alternate payee, (3) the number of payments to

which the order applies, and (4) the plan to which

the order apphes. 29 U.S.C. § 1056(d)(3)(C). If the

state court fails to substantially comply with the

statutory QDRO _ requirements, even a_e valid

domestic relations order is not enforceable against

a pension plan. See Hamilton, 433 F.3d at 1097.7

assignment of interest to anyone else or an identification of

an alternate payee; that still requires a QDRO to be effective

under ERISA. /d. at 873

7 It was argued in this appeal! that the relevant orders

entered by the Nevada family court did not satisfy this

specificity requirement, but we do not need to resolve that

Second, the DRO itself must create an

enforceable interest that is permitted under

ERISA's statutory scheme. See Hamilton, 433 F.3d

at 1097-99. Among other things, a DRO is valid

under ERISA only if it recognizes the existence of

an alternate payee's right to receive benefits

“payable with respect to a participant under a

plan.” Id. at § 1056(d)(3)(B)Q)(1). Additionally, a

DRO may not require a plan to provide any type or

form of benefit, or any option not otherwise

provided by the plan, or to provide increased

benefits to an alternate payee. Jd. at §8

1056(d)(3)(D).

The two limitations work together. The first

limitation concerns the form of the state court

order: the state DRO may create an alternate

payee's enforceable interest, but the alternate

payee may not enforce that interest unless and

until he or she has complied with the QDRO

specificity provisions. See Tise, 234 F.3d at 421.

The second limitation is_ substantive: certain

alterations to the benefits provided by a plan

governed by ERISA are forbidden. Thus, in certain

respects, ERISA limits what a state family court

can order. See Hamilton, 433 F.3d at 1098-1110.

‘

Based on these limitations, IATSE argues that

the family court's orders cannot be valid QDROs

and thus cannot divest Janis of her interest in the

QJSA's survivor benefits because the state court

issue, given our conclusion that the Nevada court's DROs did

not create interests enforceable under ERISA's scheme.

25a

orders were issued after Lupe's retirement.

According to IATSE, surviving spouse benefits

pursuant to a QJSA irrevocably vest in_ the

participant's spouse at the time of the participant's

retirement and cannot be altered or assigned.

Because Janis was Lupe's spouse at the time of his

retirement, IATSE argues that her remainder

interests vested at the time of his retirement and

no QDRO can reassign the benefits. Judy argues in

response that ERISA contains no_ provisions

limiting when a state court can issue a DRO to

transfer QJSA benefits from a surviving spouse to

an alternate payee, and therefore so long as the

state court fulfills the specificity requirements of a

QDRO it may create an enforceable interest at any

time, even after a participant's retirement.

[9] This case presents an issue of first

impression in this Circuit: whether a “plan

participant's retirement cuts off a _ putative

alternate payee's right to obtain an enforceable

QDRO” with regard to the surviving spouse

benefits of a QJSA. TJise, 234 F.3d at 423 n. 6. We

are persuaded that IATSE's interpretation is

correct and that the answer to this question is

“Yes.”

In Hopkins v. AT&T Global Info. Solutions Co..,

105 F.3d 153 (4th Cir.1997), the Fourth Circuit

addressed a set of circumstances similar to the one

presented here. In Hopkins, the ERISA plan

participant divorced his first wife, Vera, in 1986

and was ordered to pay her alimony. /d. at 154. In

order to collect the alimony, Vera obtained a

judgment allowing her to attach her ex-husband's

wages. /d. After his divorce from Vera, the

26a

participant married his’ second wife, Sherry.

Thereafter, in 1993, he retired. At that time Vera

attempted to attach both his portion of the QJSA

benefits and Sherry's surviving spouse benefits

under the QJSA. Id.

The court closely examined 29 U.S.C. § 1056

and 29 U.S.C. § 1055, which regulate QDROs and

QJSAs respectively, and concluded that surviving

spouse benefits under a QJSA vest at the time of

the participant's retirement. Jd. at 155-156. In

order to be “qualified,” and thus enforceable, a DRO

must create an alternate payee's right to benefits

“payable with respect to a participant under a

plan.” Id.; 29 U.S.C. § 1056(d)(3)(B). According to

Hopkins, if the surviving spouse benefits vested

upon the participant's retirement, the DRO would

relate to a benefit payable with respect to a

beneficiary, not payable “with respect to a

participant.” Jd. at 156. Thus, if the spouse's

interest in the benefits vested upon the

participant's retirement, the domestic relations

order could not be qualified and could not be an

exception to the preemption and antialienation

provisions. /d.

[10] The court then analyzed 29 U.S.C. § 1055

and concluded that the participant spouse's QJSA

surviving spouse rights “vest” upon the participant

spouse's retirement.® /d. Various changes to ERISA

8 The Hopkins court did not distinguish between the

annuity start date and the participant's retirement date.

Indeed, in Hopkins, like the case before us, the two dates are

the same

21a

created by the REA indicate that the participant's

retirement or the start of the annuity establishes a

vesting point for the surviving spouse benefits.

First, the REA changed the QJSA surviving spouse

benefits so that benefits may be paid to a spouse

who was married to a _ participant at the

participant's retirement, regardless of whether they

were married at the participant's death. Jd. Second,

the REA made it more difficult for a participant to

replace a QJSA with another type of benefit. The

participant could only change the benefit within

ninety days prior to retirement and with the

spouse's written consent.9 Jd. at 156-57. Unless the

participant changes the form of benefit with his

current spouse's written permission, the

participant is locked into a QJSA at retirement. /d.

at 157. Moreover, after the retirement date, the

form of benefit cannot be changed even with the

spouse's consent. Jd. Based upon the language in

ERISA, as well as the changes made under the

REA, the Fourth Circuit concluded that the plan

participant's retirement created a vested interest in

the surviving spouse, and thus Vera's DRO could

never be “qualified” for the purposes of a QDRO. Id.

Judy contends that we should not rely upon the

Fourth Circuit's reasoning in Hopkins because

another Ninth Circuit case compels an outcome in

her favor here. In 7ise, we addressed the question

whether an otherwise valid QDRO assigning other

ERISA benefits (i.e., not QJSA benefits) can issue

9 Now, the applicable time period for an election of

benefits is 180 days prior to retirement. See § 1055(c){7)(A).

28a

after the death of the plan participant. 234 F.3¢4 at

415. The plaintiff, the mother of the _ plan

participant's children, obtained a child support

judgment against the participant prior to his death.

Id. at 417-19. The plan participant died before

retirement (and after marrying the surviving

spouse), but before Tise was able to establish that

the state court order met the — specificity

requirements for a QDRO. Jd. We held that a state

court order obtained prior to a participant's death

or retirement creates an enforceable interest in the

participant's surviving spouse benefits even if the

alternate payee is unable to qualify the DRO before

the participant's death. Jd. at 423.

We came to this conclusion by analyzing the

complex ERISA framework and _ meticulously

considering the provisions of the statute that

contemplate a situation in which a valid QDRO

does not issue until after benefits become payable.

We concluded that ERISA “specifically provides for

situations in which no valid QDRO issues until

after benefits become payable. Once the pension

plan is on notice that a domestic relations order has

issued that may be a QDRO, the plan may take a

reasonable period to determine whether the order

is a QDRO....” Id. at 421. Furthermore, ERISA

provides for further state court proceedings after

the initial DRO is issued to clarify and fix any

technical defects in the original DRO. Jd. at 422

(citing 29 U.S.C. § 1056(d)(3)). Therefore, we have

held that so long as a valid DRO creates an

alternate payee's legally enforceable property

interest in QPSA benefits, a QDRO can be obtained

even after the plan participant's death. Jd. at 423.

29a

In holding that an alternate payee may obtain a

valid QDRO even after a plan participant's death,

we rejected the first part of Hopkins's logic, that

once a spouse's rights to an annuity have vested a

DRO cannot become a QDRO because the order can

no longer be “payable with respect to a participant

under a plan.” Jd. at 423-24. We concluded that

“payable with respect to a participant” includes

benefits payable to a participant as well as benefits

payable to any beneficiaries that may be eligible to

receive such benefit. See td. at 423, 423 n. 7.

Therefore, section 1056(d)(3)(B)(I) does not, in and

of itself, prohibit the assignment of surviving

spouse benefits to an alternate payee, even after a

plan participant has retired.

[11] While we recognize that 7ise expressly, and

we believe rightly, rejected part of the Fourth

Circuit's reasoning in Hopkins, we are nonetheless

persuaded by the structure and purpose of ERISA

that the rule enunciated in Hopkins is the proper

rule for QJSA benefits. Indeed, we expressly left

open this possibility. See id. at 423 n. 6, 423 n. 7

(“Whether a QDRO issued after a plan participant's

retirement may affect the distribution of surviving

spouse benefits pursuant to 29 U.S.C. § 1055

implicates statutory provisions and _ policy

considerations other than those here applicable.”).

First, ERISA's statutory scheme for QJSA

benefits establishes the importance of the annuity

start date, which is often the _ participant's

retirement date, on the benefits at issue. The plan

providers must provide participants and their

spouses with a QJSA. § 1055(a)(i). Under section

1055(c), QJSA benefits are automatically provided

30a

to employees in all ERISA-governed plans. The

only way for the participant to opt out of the QJSA

is for the participant and his spouse together to

waive the QJSA benefit plan in writing. See 29

U.S.C. § 1055(c)(1)-(2). Both spouses, if they are

going to decline QJSA benefits, may only do so

during the applicable election period which is

defined as “the 180-day period ending on the

annuity starting date.”!9 Jd. at § 1055(c)(2), (7).

Thus, the annuity starting date, which in this case

is Lupe's retirement date, is the point at which the

surviving spouse benefits vest in the participant's

spouse.!!

10 This statutory construction makes it difficult to adopt

the alternative rule that Judy urges. It is difficult to see how

courts may reassign QJSA surviving spouse benefits at any

time given the fact that the statutory scheme so diligently

and strictly protects the interests of the participant's spouse

at the time of the participant's retirement by establishing

that the only way to avoid QJSA survivor benefits is by opting

out in writing before the retirement date.

11 The terms of the IATSE plan itself also suggest that

the surviving spouse's interest vests at the time of Lupe's

retirement. The plan informed Lupe that he would

automatically be paid in the form of a QJSA if he was married

at least 12 months prior to the benefit starting date (his

retirement) unless he chose otherwise. It also established that

the exact amount of monthly benefits payable to him and his

spouse under the QJSA depended upon “the relative ages of

you and your spouse at the time of your retirement

(emphasis added). Thus the plan established both that the

type of plan and the amount of benefits were calculated at the

time of retirement and the amount was calculated based on

the relative ages co him and his spouse. This structure

3la

[12] We are also persuaded, as was the Fourth

Circuit in Hopkins, that a number of changes in

ERISA, effectuated by the REA, established the

importance of the participant's date of retirement

as the moment at which the surviving spouse

benefits vest. The fact that the REa established

that surviving spouse benefits may now be paid toa

spouse who is married on the day of the

participant's retirement, regardless of whether the

participant and spouse are married at the

participant's death, suggests that the retirement

date is the crucial date for establishing the rights of

the surviving spouse. Hopkins, 105 F.3d at 156.

Following this reasoning, we conclude that once a

participant retires, the spouse at the time becomes

the “surviving spouse” entitled to the QJSA

benefits.

In addition to finding support for the Hopkins

rule from the statutory scheme, we are also

persuaded that the ultimate objectives of Congress

are served by recognizing the rule that a QDRO

may not reassign surviving spouse benefits after a

plan participant has retired. See Hamilton, 433

F.3d at 1099 (noting that congressional intent

ultimately determines whether or not a particular

statutory interpretation applies to surviving spouse

benefits); Boggs, 520 U.S. at 843, 117 S.Ct. 1754

(considering congressional intent when analyzing

qualified joint and survivor annuity benefits).

suggests that the benefits vested at retirement in the

surviving spouse.

32a

ERISA's surviving spouse benefits established

in section 1055 were created in part “to ensure a

stream of income to surviving spouses.” Boggs, 520

U.S. at 843, 117 S.Ct. 1754. Specifically, Congress

was concerned with providing for spouses that were

not able to accrue their own set of retirement

benefits independent from their working spouses.

Prior to ERISA there was no requirement that

retirement plans provide for an employec's spouse

in the event that the employee predeceased a

spouse not working outside the home (“non-working

spouse’). Congress concluded that such a regime

“{could] result in a hardship where an individual

primarily dependent on his pension as a source of

retirement income is unable to make adequate

provision for his spouse's retirement years should

he predecease her.” H.R.Rep. No. 93-807, at 4732

(1974), reprinted in 1974 U.S.C.C.A.N. 4670, 4732.

Likewise, in amending ERISA through the REA,

Congress adopted changes to the statutory scheme

to take into account “changes in work patterns, the

status of marriage as an economic partnership, and

the substantial contribution to that partnership of

spouses who work both in and outside the home.”

Retirement Equity Act of 1984, Pub.L. No. 98-397,

98 Stat. 1426 (codified as amended in scattered

sections of 29 U.S.C.). Congress created surviving

spouse benefits, like those found in QJSAs, to

protect non-participant spouses, particularly those

that may not work outside the home and thus may

not have independent retirement benefits.

The Hopkins rule applied in this case may not

clearly protect a non-working spouse whose interest

in the surviving spouse benefits may have accrued

over time, since Lupe was not married to either

33a

Janis or Judy during most of his working years

when he earned the pension benefits. Nonetheless,

such a rule would protect a non-working spouse in

many situations involving a_ post-retirement

attempt to transfer surviving spouse benefits. The

finely tuned congressional scheme would not be

served by state court DROs that attempt to divest a

non-working spouse's interest in her surviving

spouse benefits. Similarly, congressional intent is

not advanced by permitting a subsequent post-

retirement spouse to collect benefits accrued during

an economic partnership she or he was not a part

of.}2

Additionally, a vesting rule also promotes one of

the principal goals underlying ERISA: “ensuring

that plans be uniform in their interpretation and

simple in their application.” McGowan v. NJR Serv.

Corp., 423 F.3d 241, 246 (3d Cir.2005) (internal

12 We note that this view is advanced by the legislative

history of the REA. The Senate Report notes that in theory “a

qualified domestic relations order could provide that the

former spouse is not entitled to any survivor benefits under

the plan.” S.Rep. No. 98-575, at 15 (1984), reprinted in 1984

U.S.C.C.A.N. 2547, 2562. While we recognize that this

passing note contradicts our conclusion that Janis's surviving

spouse benefits vested at Lupe's retirement, we are

nonetheless convinced that the structure of the statute, the

purposes and policies undergirding ERISA, and the authority

from other jurisdictions following this interpretation support

our conclusion. Furthermore the note does not contradict the

outcome here because Lupe did not seek to divest Janis of her

surviving spouse rights, but rather attempted to replace her

with Judy, something that neither the statutory language nor

the legislative history permits.

34a

quotation marks and citations omitted), abrogated

on other grounds by Kennedy, --- U.S. ----, 129 S.Ct.

865, 172 L.Ed.2d 662. While administrative

convenience is not entirely determinative of what is

required of pension plans under ERISA, we are

convinced that it should be a consideration when

deciding whether the statutory scheme requires

pension plans to act in a certain way.

Both the participant's post-retirement pension

benefits and surviving spouse benefits under the

QJSA are calculated based upon the life of the two

spouses at the time the benefits become payable.

The benefits payable to each are computed based

upon the “actuarial equivalent of a single annuity

for the life of the participant.” 29 U.S.C. §&

1055(d){1)(A)-(B) (establishing that the participant

receives pension benefits “for the life of the

participant with a survivor annuity for the life of

the spouse which is not less than 50 percent of ...

the amount of the annuity which is payable during

the joint hves of the participant and the spouse’).

The calculation and payment of the _ pension

benefits mean that it is important for the plan

administrators to know, with some finality, who the

spouse 1s at the time that the benefits become

payable:

Because the disbursement of plan benefits is

based on actuarial computations, the plan

administrator must know the life expectancy

of the person receiving the Surviving Spouse

Benefits to determine the _ participant's

monthly Pension Benefits. As a result, the

plan administrator needs to know, on the

ae,

wiere

day the participant retires, to whom the

Surviving Spouse Benefit is payable

Hopktns, 1O5 F.3d_sat 157 on / Allowing

participants to change surviving spouse

beneficiaries after the participant has retired and

already begun receiving benefit payments would

make it difficult for trustees to administer plan:

based on the actuarial value of both the participant

and the surviving spouse. We therefore agree with

Hopkins, as well as with other courts that have

either implicitly or explicitly concluded that the

surviving spouse benefits irrevocably vest in the

current spouse when the plan participant retires

See Hopkins, 105 F.3d at 157; see also Rivers |

Central and South West Corp., 186 F.3d 681 (5th

Cir.1999); Walsh v. Woods, 371 S.C. 319, 638 S.E.2d

85 (2006): Hamilton, 433 F.3d at 1096 (noting that

problems in QDROs often go undetected “until the

participant dies or retires, that is, when the

survivor benefits irrevocably vest in the current

spouse and it 1s too late to do anything about it”)

(quotation omitted); Anderson v. Marshall, 856

F Supp. 604, 607 (D.Kan.1994):; cf. Fox Valley &

Vicinity Constr. Workers Pension Fund v. Brown,

$97 F.2d 275 (7th Cir.1990) (en banc) (allowing the

waiver of surviving spouse benefits as required in a

divorce decree entered prior to the participant’

retirement); but see Torres v. Torres, 100 Hawaii

397, 60 P.3d 798 (Haw.2003)

[13] Because the retirement of a plan

participant ordinarily creates a vested interest in

the surviving spouse at the time of the participant’:

retirement, we conclude that a DRO issued after

the participant's retirement may not alter or assign

36a

the surviving spouse's interest to a subsequent

spouse. The Nevada family court's attempted

transfer of interests in Janis's surviving spouse

benefits to Judy is prohibited

It is important to note that this opinion does not

disturb our prior holding in TJise. Fundamentally,

Tise answers a very different question from the one

presented here. In Tise, we determined when a

DRO, which creates an enforceable interest in an

alternate payee, can be “qualified” for QPSA

benefits. Tise established that a _ state court

domestic relations order may be qualified even

after a participant's death, “[b]ecause a QDRO only

renders enforceable an already-existing interest.”

234 F.3d at 421. In contrast, here we ask whether

there are any restrictions as to when a state can

create an enforceable interest in an alternate payee

for QJSA surviving spouse benefits. We hold here

only that a state DRO may not create an

enforceable interest in surviving spouse benefits to

an alternate payee after a participant's retirement,

because ordinarily at retirement the surviving

spouse's interest irrevocably vests.}%

13° We say “ordinarily” because we recognize that there

may be other situations, not present in this case, in which a

contrary result may be appropriate. For example, it is

possible that a former spouse could obtain a DRO prior to the

annuity start date and present it to the plan, but the actual

determination of whether the DRO is a QDRO might not be

finalized prior to the date on which the benefit would

normally become payable. See, e.g., 29 U.S.C. § 1056(d)(3)(H).

37a

Additionally, ERISA only permits state court

DROs to reassign surviving spouse benefits if they

meet the requirements of 29 U.S.C. § 1056(d)(3)(F).

Hamilton, 433 F.3d at 1099. Section 1056(d)(3)(F)

governs the use of QDROs to reassign benefits

pursuant to 29 U.S.C. § 1055 and states that “to the

extent provided in any qualified domestic relations

order the former spouse of a participant shal! be

treated as a surviving spouse of such participant....”

We have interpreted this provision as permitting a

transfer of surviving spouse benefits established

under section 1055 only if the QDRO expressly

assigns surviving spouse rights to a former spouse.

See Hamilton, 433 F.3d at 1099. Here, Judy is nota

“former spouse” but rather is a “future” or

“subsequent spouse” because she married Lupe

after his retirement. See Hopkins, 105 F.3d at 157

n. 6. No part of ERISA contemplates reassignment

of surviving spouse benefits to a _ future or

subsequent spouse. We take Congress's silence with

respect to the rights of a future or subsequent

spouse to obtain control of surviving spouse

benefits as “powerful support for the conclusion

that the right does not exist.” Boggs, 520 U.S. at

847-48, 117 S.Ct. 1754.

Judy also argues that Janis waived her right to

the surviving spouse benefits by the property

settlement when the state court entered its divorce

decree. As the Supreme Court made clear in

Kennedy, ERISA's antialienation provision does not

prohibit a surviving spouse beneficiary from

waiving his or her interest in plan benefits, but

such a waiver must also conform to plan procedures

and instruments. Indeed, the Court concluded that

the plan administrator in that case was not, under

38a

the terms of the plan, required to honor the waiver

of benefits contained in the divorce decree and that

the continued payment of benefits to the prior

spouse was proper. See Kennedy, 129 S.Ct. at 874-

78. Under the so-called “plan documents rule,” plan

administrators must “hew[ ] to the directives of the

plan documents” rather than “examin{ing] a

multitude of external documents that might

purport to affect the dispensation of benefits” and

becoming “drawn into litigation like this over the

meaning and enforceability of purported waivers.”

Id. at 876, 877 (internal quotation marks omitted).

Both the IATSE plan documents and ERISA's

statutory scheme allow for the waiver of surviving

spouse benefits with both spouses' written consent

during the benefits election period prior to the

participant's retirement. 29 U.S.C. § 1055(c)(8).

That procedure was not followed here. Judy has

identified nothing in the IATSE plan documents

which require the plan administrator to redirect

surviving spouse benefits to Judy, who was not, at

the time of retirement and vesting, either a present

or former spouse. Even if it is assumed that Janis

had the authority to disclaim benefits, there is

nothing that provides for them to be assigned

instead to Judy.

C. The Constructive Trust

[ATSE also contends that it was impermissible

for the state court to create a constructive trust on

the annuity proceeds. We agree that a state law

constructive trust cannot be used to contravene the

dictates of ERISA.

39a

ERISA preemption supercedes “any and all

state laws insofar as they may now or hereafter

relate to any employee benefit plan” covered by

ERISA. 29 U.S.C. § 1144(a). The Supreme Court

has observed that the preemption provision 1s

“clearly expansive” but that it cannot be taken “te

extend to the furthest stretch of its indeterminacy.”

Egelhoff v. Egelhoff, 532 U.S. 141, 146, 121 S.Ct.

1322, 149 L.Ed.2d 264 (2001) (citations and

internal quotation marks omitted). A state law

“relates to an ERISA plan if it has a connection

with or reference to such a plan.” Jd. at 147, 121

S.Ct. 1322 (citations and internal quotation marks

omitted). To determine whether a state law is

preempted because it relates to an ERISA plan, the

courts look to the nature and effect of the state law

on ERISA plans as well as the objectives of the

ERISA statute. Jd.

In Melton v. Melton, the Seventh Circuit

observed that “Egelhoff stands for the proposition

that a state law cannot invalidate an ERISA plan

beneficiary designation by mandating distribution

to another person.” 324 F.3d 941, 945 (7th

Cir.2003) (citations omitted). The court applied that

proposition to conclude that ERISA preempted a

state court law that permitted the imposition of a

constructive trust on ERISA proceeds. It concluded

that the imposition of a constructive trust to

subvert ERISA-mandated beneficiaries was directly

controlled by Egelhoff and preempted by ERISA. Id.

Thus the court held that state law doctrines

(including constructive trusts) may not be invoked

to assign benefits to parties other than those

designated as beneficiaries under ERISA. Jd.

40a

Furthermore, as the Supreme Court concluded

in Boggs, ERISA can preempt state law even after

benefits have been disbursed to beneficiaries. 520

U.S. at 842 (rejecting the argument that state law

can apply when it affects “only the disposition of

plan proceeds after they have been disbursed by

[the plan] and thus nothing is required of the

plan”). Therefore a state court cannot achieve

through a constructive trust on the proceeds of a

pension plan what this court maintains it cannot

achieve through a QDRO. Any alternative rule

would allow for an end-run around ERISA's rules

and Congress's policy objective of providing for

certain beneficiaries, thereby greatly weakening, if

not entirely abrogating, ERISA's broad preemption

provision.

Judy relies upon our decision in Emard uv.

Hughes Aurcraft Co., 153 F.3d 949 (9th Cir.1998),

for the proposition that once a plan distributes

proceeds to the proper ERISA beneficiary, a state

law created constructive trust is too attenuated to

fall within the mandatory preemption provision. Id.

at 954. Emard, however, was abrogated by

Egelhoff, 532 U.S. 141, 121 S.Ct. 1322, 149 L.Ed.2d

264, and thus Emard's holding, to the extent it can

be interpreted as an end-run around ERISA's

mandates, no longer survives.!4

14 Additionally, Emard addressed insurdaiice benefits

and not pension plan benefits. Emard, 153 F.3d at 953. As

noted in Guidry v. Sheet Metal Workers Nat'l Pension Fund,

493 US. 365, 110 S.Ct. 680, 107 L.Ed.2d 782 (1990), ERISA's

antialienation provision applies only to pension benefits and

not welfare benefits. Thus an independent reason (the

4la

[14] In this case, the constructive trust that the

state court created was explicitly an attempt to

avoid ERISA's QDRO, preemption, and

antialienation provisions. We conclude _ that

Congress did not intend to permit the reassignment

of surviving spouse benefits and, therefore the

constructive trust remedy that the state court tried

to impose is also preempted by ERISA. It may not

be that all constructive trusts instituted by state

courts, particularly those that seek to recover ill-

gotten gains, will have a sufficient connection with

or reference to an ERISA plan to trigger ERISA's

preemption provision.!® But when a state court

creates a constructive trust with the explicit

purpose of avoiding ERISA's rules, it too must be

preempted.

antialienation provision) prohibits the use of constructive

trusts to garnish pension benefits in this case. See id. at 371-

72, 110 S.Ct. 680. In Guidry, the Supreme Court concluded

that a constructive trust could not be used to disgorge a

pension plan fiduciary's ill-gotten gains because it was

prohibited by the antialienation provision of ERISA and did

not meet any of the statutory exceptions to the ERISA

provision. See id. at 372-376, 110 S.Ct. 680. On remand, the

Tenth Circuit upheld the imposition of a constructive trust

and concluded that ERISA did not prohibit post-payment

garnishment of ill-gotten gains. See Guidry v. Sheet Metal

Workers Nat'l. Pension Fund, 39 F.3d 1078 (0th Cir.1994)

(en banc). This decision, too, preceded both Egelhoff and

Boggs, and may not survive.

15 In Kennedy, the Court explicitly declined to express a

view on whether an action could have been brought to obtain

benefits from the former spouse after they had_ been

distributed to her. 129 S.Ct. at 875 n. 10.

42a

Congress, through ERISA, has created a set of

fixed property rules state courts are bound to work

within. State family courts can and_ should

distribute property in an equitable manner upon

divorce, but they must take into account ERISA's

rules. ERISA prohibits the state family court from

steering the surviving spouse benefits from Janis to

Judy, but ERISA did not prohibit the state court

from dividing other property or making other

adjustments mindful of the benefits provided under

the ERISA plan. In this instance, the state family

court provided for a transfer of $1500 from Lupe to

Janis based upon the premise that Lupe and Janis

would each retain their pension benefits as

separate property. That premise may have been

faulty, but that does not justify disregarding the

ERISA limitations.

lil. Conclusion

We conclude that Janis's lawsuit against both

Hilton and Judy was properly dismissed by the

district court for lack of subject matter jurisdiction.

Although Janis may have been right on the

underlying substantive issue, she already had her

day in court on the question and, under the

circumstances, 1s barred under the Rooker-Feldman

doctrine from seeking recourse in federal court at

this time.

IATSE’'s similar argument is not’ barred,

however. We agree with its contention that it is not

required to make payment of the surviving spouse

benefits to Judy or to the constructive trust ordered

by the Nevada family court. Under ERISA, Janis's

interest in the surviving spouse benefits vested at

Lupe's retirement and federal law preempted the

state court orders directing the plans to change the

beneficiaries and creating a constructive trust.

We remand the matter to the district court for

whatever further proceedings may be necessary

and appropriate. Each party is to bear its own costs

on appeal.

AFFIRMED in part, REVERSED in part,

and REMANDED.

44a

APPENDIX B

UNITED STATES DISTRICT COURT

DISTRICT OF NEVADA

No. CV-S-04-1310-KJD-RJJ

JANIS CARMONA, A.K.A. JANIS KESTER.

Plaintiff,

HILTON HOTELS CORPORATION, RETIREMENT PLAN:

JUDY CARMONA,

Defendants,

September 30, 2005

ORDER

Presently before the Court is Defendant Judy

Carmona's Motion to Dismiss the Amended

Complaint and Cross-Claim (# 31). Plaintiff filed a

response in opposition (## 33). Defendant Trustees

of the Nevada Resort Association International

Alliance of Theatrical and Stage Employees

45a

(““IATSE Trustees”) also filed a response in

opposition (# 32). Defendant Judy Carmona's

motion and the oppositions all incorporated by

reference the previous filings on Defendant Judy

Carmona's Motion to Dismiss the Complaint # 4)

and Motion to Dismiss the Cross-Claim (# 18). The

Court has considered all the briefs and exhibits

filed in opposition to those motions and _ the

corresponding replies and sur-replies.

The Court has also considered Defendant Judy

Carmona's Motion for Extension of Time to File

Opposition to the Motions for Summary Judgment

(# 39). The Court GRANTS the motion to the

extent that it seeks an extension of time to file an

opposition to the IATSE Trustees’ Motion for

Summary Judgment (# 34). The remaining portions

of the motion are DENIED as moot, because

Defendant Judy Carmona voluntarily withdrew

them.

I. Facts and Procedural History

This dispute concerns the survivorship benefits

from Lupe N. Carmona's (“LUPE”) pension plans

with the IATSE ‘Trustees and Hilton Hotels

Retirement Plan (“HILTON”). Lupe originally

designated Plaintiff Jamis Carmona as_ the

beneficiary of these plans, but he later petitioned

the Clark County District Court, Family Division

(“Family Court’) for an order directing the pension

plans to pay those benefits to Defendant Judy

Carmona. Since that time the parties have litigated

this issue at every level of state court as well as in

Federal District Court, Federal Bankruptcy Court,

the United States Supreme Court, and no doubt,

46a

will argue the merits of this order before the Ninth

Circuit Court of Appeals.

Lupe and Plaintiff married on March 7, 1988.

On September 3, 1992, Lupe named Plaintiff as the

beneficiary of survivor benefits on both fire

HILTON and IATSE plans. Lupe retired on

October 1, 992. On October 27, 1994, Lupe filed for

divorce in Family Court. Prior to the divorce, both

Lupe and Plaintiff contacted IATSE and HILTON

to inquire whether he could change her as

beneficiary. The providers informed them verbally

and in writing that Plaintiffs designation as

beneficiary was irrevocable.

Pursuant to a settlement conference, the Famuly

Court granted Lupe both his I[ATSE and HILTON

pensions as his sole and separate property. During

the marriage, Lupe's benefits in his pension plans

had increased more than Plaintiff's own pension.

The Family Court ordered Lupe to pay Plaintiff

$1,500.00 “as and for an equalization of the values

of the marital portion of the pensions divided

herein.” After the divorce, Lupe petitioned the

Family Court for a Qualified Domestic Relations

Order (“QDRO”) revoking Plaintiffs designation as

the beneficiary.

Lupe and Defendant Judy Carmona were

married on November 30, 1997. That same month,

Lupe filed a motion asking the Family Court to

create a constructive trust for the benefit of his new

wife, Defendant Judy Carmona. Lupe contended

that the divorce decree awarded him the entirety of

both pension plans, including the survivor benefits.

He further asserted that Plaintiff would be unjustly

enriched if she dispossessed him of this property.

Plaintiff claimed that survivor benefits are not

death benefits, but an irrevocable interest unde:

both the IATSE and HILTON plans, and thus they

were her sole property. On March 25, 1998, the

Family Court held Plaintiff had not waived he:

rights to the survivor benefits, but the providers

could change Defendant's designation as

beneficiary if they chose.

However, one day after Lupe's death on April

15, 1999, the Family court ordered’ the

administrators of the IATSE and HILTON plans to

change the beneficiary designation pursuant to

Lupe's directions. The Family Court stated that it

would order the establishment of a constructive

trust for Defendant Judy Carmona's benefit if the

administrators failed to make the change. Plaintiff

argued that after Lupe's death, he and his estate

were divested of any further interest in the pension

plans, leaving Defendant Judy Carmona with no

interest in the survivor benefits because those

benefits were now vested in Plaintiff.

Plaintiff appealed the Family Court's orders to

the Nevada Supreme Court. @n October 21, 2003,

the Nevada Supreme Court affirmed the Family

Court's order establishing a constructive trust. It

found the divorce decree awarded Lupe his pension

rights including the survivor benefits. The Court

also addressed Plaintiff's argument that the

Employee Retirement Income _ Security Act

(“ERISA”) preempted the Family Court's creation of

a constructive trust relating to ERISA regulated

benefits. The Court stated that although ERISA

prohibits alienation of benefits other than to the

4a

designated participant or survivor beneficiary, the

Retirement Equity Act (“REA”) of 1984 provided an

exception to ERISA's anti-alienation provision,

which allowed the designation of an alternate

payee through a QDRO

The Nevada Supreme Court also found Plaintiff

had waived her rights to the survivor benefits from

Lupe's plans upon her receipt of the $1,500.00

payment. Additionally, it found the Family Court's

creation of the constructive trust was essential to

effectuate Lupe's wishes and it would be

inequitable to allow Plaintiff to retain the benefits

because she was no longer married to Lupe at the

time of his death

Plaintiff appealed this decision to the United

States Supreme Court. On April 19, 2004, the

United States Supreme Court denied certiorari. In

addition to Plaintiffs appeals to the Nevada

Supreme Court and the United States Supreme

Court, on February 4, 2004, a United State

Bankruptcy Court held that Plaintiff did not have a

legal or equitable interest in the survivor benefits

Further, in two separate prior actions, this Court

has denied Plaintiff relief. On August 14, 2001,

Chief Judge Philip M. Pro held that because ERISA

permitted state and federal courts to exercise

concurrent jurisdiction, the Court would not

“relitigate issues where another court had

jurisdiction and made a@ final determination.’

Kester 1 Gaston. Case No CV-S-01-0431-PMP

(PAL), Order, Doc. # 36 at 4 (D.Nev. Aug. 14, 2001)

49a

Then, on April 2, 2004, the Family Court issued

an order requiring Plaintiff to deposit the survivor

benefit funds she received into a constructive trust

The Family Court noted that both the Bankruptcy

Court and the Nevada Supreme Court had ruled

the funds in question were not Plaintiff's property

That same day, the Family Court entered two

QDRO's ordering the two plans to pay the survivor

benefits either to Defendant Judy Carmona or to a

constructive trust account for Defendant Judy

Carmona's benefit. On April 28, 2004, Plaintiff filed

a Notice of Removal in Federal District Court for

the District of Nevada. See Carmona v. Carmona,

Case No. CV-S-04-0534-PMP (RJJ), Petition for

Removal, Doc. # 1 (D.Nev.)

On August 25, 2004, the Court remanded the

action back to Family Court. The Court found that

Plaintiff had failed to timely remove the case, and

had waived her right to remove the ERISA claim

See id. at 6. The Court recited part of its previous

order in CV-S-01-0431-PMP notifying Plaintiff that

a “United States District Court does not have the

authority to review a final judgment” of a state

court proceeding citing Rooker vu. Fidelity Trust Co.,

263 U.S. 413 (1923) and Dist. of Columbia Court o/

Appeals v. Feldman, 460 U.S. 462 (1983). Id. at 7

Now, Plaintiff has filed suit in Federa] District

Court for the third time. In an attempt to avoid the

results of claim and issue preclusion as well as the

Rooker-Feldman doctrine, Plaintiff has brought suit

alleging exclusive federal court jurisdiction and has

named the two pension trust funds as defendants

In addition to Defendant Judy Carmona

Additionally, the [ATSE ‘Trustees have filed

50a

cross-claim against Defendant Judy Carmona

seeking declaratory relief. Defendant Judy

Carmona has filed a motion to dismiss Plaintiff's

complaint and IATSE's cross-claim. Essentially,

Defendant Carmona asserts that res judicata and

the Rooker-Feldman doctrine preclude’ those

claims.

Il. Rooker-Feldman Doctrine

A. Application to Plaintiff's Complaint

The Rooker-Feldman doctrine is based on the

statutory proposition that federal district courts are

courts of original, not appellate jurisdiction. See In

re Sasson, 2005 WL 2210195 (9th Cir.2005)(citing

28 U.S.C. § 1331, 1332). Therefore, federal district

courts have “no authority to review the final

determinations of a_ state court in_ judicial

proceedings.” Worldwide Church of God v. McNair,

805 F.2d 888, 890 (9th Cir.1986). Only the Supreme

Court has original jurisdiction to review the final

judgments or decrees rendered by the highest state

court of a state in which a decision could be had.

See Sasson at 5 (citing 28 U.S.C. § 1257(a)).

The United States Supreme Court has recently

clarified the limit of the Rooker-Feldman doctrine:

“The Rooker-Feldman doctrine ... is confined to

cases of the kind from which the doctrine acquired

its name: cases brought by state-court losers

complaining of injuries caused by state-court

judgments rendered before the district court

proceedings commenced and inviting district court

review and rejection of those judgments.” Exxon

Mobil Corporation v. Saudi Basic Inds. Corp., 125

5la

S.Ct. 1517, 1521-22 (2005). Therefore, three factors

must exist in the present action for the Court to

find that it lacks subject matter jurisdiction over

the claims raised by Plaintiff. First, the case must

be brought by a state-court loser. Second, the state-

court loser must be complaining of injuries caused

by state-court judgments rendered before the

district court proceedings commenced. Finally, the

complaint must invite review and rejection of the

state-court judgments.

All three factors are satisfied in this case, and

thus, this Court lacks subject matter jurisdiction

over Plaintiff's complaint. First, Plaintiff is a state-

court loser. Plaintiff is complaining of’ injuries

caused by the state court judgments: primarily, the

Nevada Supreme Court's determination that the

state court action was not preempted by ERISA

and that Plaintiff had executed a valid waiver of

her spousal interest in Lupe's pension. That

determination was rendered on October 21, 2003

before Plaintiffs claim was filed in this action on

September 20, 2004. Finally, though Plaintiff

attempts to artfully draft the complaint, it is clear

from the pleadings that Plaintiff is inviting this

Court to review and reject the determinations of

the Nevada Supreme Court. Plaintiff's complaint is

the classic case where the Rooker-Feldman doctrine

declares such suits “out of bounds”,! and it must be

1 Plaintiff has asserted that as pled the complaint

arises under the exclusive jurisdiction of this Court and as

such, an exception applies barring application of the Rooker-

Feldman doctrine. See G.C. and K.B. Investments v. Wilson,

326 F.3d 1096, 1103 n. 4 (9th Cir.2003). However, that

argument ignores the fact that concurrent jurisdiction existed

52a

dismissed for want of subject-matter jurisdiction

See id. at 1521.

B. Application to IATSE's Cross-claim

However, Rooker-Feldman does not bar IATSE's

cross-claim. Despite Defendant Judy Carmona's

strident assertions that the IATSE Trustees should

be considered in privity with Plaintiff, Defendant

Judy Carmona has not cited the Court to any

relevant legal authority that leads to that

conclusion. Rooker-Feldman bars only the losing

party in the state suit, and has no application to a

federal suit brought by a nonparty to the state suit.

See id. at 1523 (citing Johnson v. De Grandy, 512

U.S. 997, 1005-1006 (1994)).

Furthermore, the principles of res judicata do

not bar IATSE's cross-claim for the same reason. A

federal action may be barred by the doctrine of res

judicata where an earlier lawsuit: (1) involved the

same claim as the present suit; (2) reached a final

judgment on the merits; and (3) involved the same

parties or their privies. See Blonder-Tongue

Laboratories v. Univ. Of Ill. Found., 402 U.S. 313,

323-324 (1971). A person may be precluded from

pursuing a claim if a prior party so closely

represented his legal interests as to be his virtual

when the action was proceeding in state court Inexplicably,

the parties failed to remove the action before the thirty-day

limit expired leading this Court to find in CV-S-04-0534-PMP

that Plaintiff had waived her right to removal of the ERISA

claim Thus Plaintiff implicitly subjected herself to the final

determination of the state court.

53a

representative. See Nordhorn v. Ladish Co., Inc ., 9

F.3d 1402 (9th Cir.1993). Defendant Judy Carmona

has not adequately established that Plaintiff so

closely represented the IATSE Trustees' legal

interests as to be their virtual representative.

Therefore, the Court declines to dismiss the [ATSE

Trustees’ cross-claim.

However, the Court recognizes that the IATSIK

Trustees and HILTON could have prevented some

of the extensive and unnecessary litigation in this

matter simply by interpieading the funds in issue

and seeking a determination as to whether their

determinations that the domestic relations orders

in dispute were qualified or not were accurate.

Certainly such a course of action would have been

more prudent than filing a cross-claim that could

subject the pension funds to an award of attorney's

fees by taking an adversarial stance rather than by

proceeding as a “neutral stakeholder in a typical

statutory interpleader action.” Trustees of the

Directors Guild of America-Producer Pension

Benefits Plans v. Tise, 234 F.3d 415, 427 (9th

Cir.2000). In fact, the parties seem to be

positioning themselves to resolve the issue of

whether the plan participant's retirement cuts off a

putative alternate payee's right to obtain an

enforceable QDRO, an issue the Tise court

2 29 USC. § 1056(d)(3)CGH)d) allows a court of

competent jurisdiction to determine whether a state court's

order meets the statutory requirements to be a QDRO. See,

also, Trustees of the Directors Guild of America-Producer

Pension Benefits Plans v. Tise, 234 F.3d 415, 421, 426 (9th

Cir.2000).

54a

recognized was unresolved in the Ninth Circuit. See

id. at 423 n. 6.

IIL. Conclusion

Accordingly, IT IS HEREBY ORDERED that

Defendant Judy Carmona's Motion to Dismiss (# 4)

is DENIED as moot;

IT IS FURTHER ORDERED that Defendant

IATSE Trustee's Motion to Expedite Diuspositive

Motion Practice (# 8) is GRANTED;

IT IS FURTHER ORDERED that Defendant

IATSE Trustee's Motion to Stay State Court

Proceedings (# 9) is DENIED;

IT IS FURTHER ORDERED that Defendant

Judy Carmona's Motion to Dismiss Cross-claim (#

18) :s DENIED as moot;

IT IS FURTHER ORDERED that Defendant

Judy Carmona's Motion to Exceed Length of Reply

(# 21) is GRANTED;

IT IS FURTHER ORDERED that Defendant

Judy Carmona's Motion to Dismiss Amended

Complaint and Cross-claim (# 31) is GRANTED in

part and DENIED in part;

IT IS FURTHER ORDERED that Plaintiff's

complaint is DISMISSED;

IT IS FURTHER ORDERED that Defendant

Judy Carmona's Motion to Dismiss the Cross-claim

is DENIED;

Iva

IT IS FURTHER ORDERED that Plaintifi's

Motion for Summary Judgment (# 35) is DENIED

as moot;

IT IS FURTHER ORDERED that Defendant

Judy Carmona's Motion for Extension of Time to

File an Opposition to Cross-Claimant's Motion for

Summary Judgment (# 39) is GRANTED;

IT IS FURTHER ORDERED that Motions (# 41,

42. 43, 52, 57 and 62) are DENIED as moot;

IT 1S FURTHER ORDERED that Defendant

Judy Carmona's Motion to Withdraw

Countermotion (# 44) is GRANTED.

DATED this 30th day of September 2005.

si,

Kent J. Dawson

United States District Judge

56a

APPENDIX C

SUPREME COURT OF -TEVADA

No. 35851

JANIS CARMONA, A.K.A. JANIS KESTER,

Plaintiff, |

JUDY CARMONA. AS SUCCESSOR REPRESENTATIVE OF

LUPE N. CARMONA, DECEASED,

Respondent. |

October 21, 2003.

ORDER OF AFFIRMANCE

These are two consolidated appeals from several

district court orders in the same district court case.

The orders appealed from impose a constructive

trust on survivor benefits, designate a successor

representative, and award attorney fees.

ry

Sila

Lupe Carmona was formerly married _ to

appellant Janis Carmona. Before marring Janis,

Lupe worked for the International Alliance of

Theatrical Stage Employees (IATSE). During

marriage, both Lupe and Jamis worked for the

Hilton Hotel Corporation. Lupe was eligible for

pension benefits with IATSE and the Hilton Hotel

Corporation and elected the qualified joint and

survivor annuity (QJSA) option for married couples

on his pensions. Janis was lsted as his survivor

beneficiary for both plans. Lupe retired in 1992 and

began receiving payments from his pensions.

In November 1997, Lupe and Janis divorced. In

the divorce decree, Lupe was awarded his pensions

as his separate property, but was ordered to pay

Janis $1,500 for her marital portion of his pension.

After Lupe married respondent Judy

Walkington shortly after his divorce from Janis, he

tried to change the designation of his survivor

beneficiary from Janis to Judy. However,

representatives of both Hilton Hotel and IATSE

informed Lupe that a change of beneficiary after

commencement of retirement is prohibited. The

Hilton Hotel representative added that the

Employee Retirement Income Security Act (RISA)

prohibits such a change, unless a Qualified

Domestic Relations Order (QDRO) “which waives

the spouse's right to survivor benefits is served on

the Plan.” Accordingly, Lupe requested the district

court to enter a QDRO ordering his pension plan

administrators to grant his election of a new

survivor benef ciary.

58a

At first, the district court refused to issue a

QDRO that changed the _ beneficiary. But

subsequently, after Lupe's death, the district court

found that the parties had agreed that Lupe's

retirement benefits, including the survivor benefits,

were his sole and separate property. The district

court ordered the plan administrators to change the

survivor beneficiary in accordance with Lupe's

request, and if they did not, the district court

stated that it “will Order the establishment of a

Constructive Trust for the benefit of Lupe's

designated beneficiary wherein the survivorship

funds, if received by Janis, will be held in trust for

receipt by Lupe's designated beneficiary.” The

district court subsequently issued an order

directing Janis to establish a constructive trust of

the survivorship funds from Lupe's-retirement

plans for the benefit of Judy. Janis appeals.!

Janis's argument that the district court's first

order refusing to impose a QDRO is res judicata

has no merit. In the first order, the district court

refused to issue the QDRO, but with additional

information and arguments, the court could and did

issue a QDRO. The first order was not final as is

required for res judicata to apply. There was

nothing inconsistent between the two orders, either

in law or fact.

1 ~=6dudy argues that Janis's appeal of the district court's

April 16, 1999 order and constructive trust order of June 22,

1999, should be dismissed because Janis's notice of appeal of

March 21, 2000, was untimely pursuant to NRAP 4. Judy's

argument is without merit as Janis's motions were tolling

motions under NRCP 52(b) and NRCP 59. See NRAP 4(a)(2).

59a

Janis's argument that the constructive trust

unlawfully modifies the divorce decree is also

without merit. The constructive trust does not

modify the divorce decree since the district court

concluded that in the divorce decree, Lupe's

pension rights, including the survivor benefits,

were awarded as his sole and separate property.

Janis argues that all district court orders

entered during the period in which there was no

designated successor representative for Lupe are

void. Before a judgment may affect a deceased

party's estate, the personal representative of the

deceased party must be substituted as a party.”

Without such substitution, a judgment is voidable.*

However, in this case, two months after Judy was

substituted, the district court reconsidered all the

orders issued during the time there was no

successor representative. Therefore, the district

court's orders are not void.

Janis's most important argument is that ERISA

preempts the district court's orders and _ the

constructive trust relating to ERISA-regulated

benefits. Both of Lupe's pensions are regulated by

ERISA, and interplay between ERISA and state

law is not always clear. ERISA specifically provides

that it “shall supercede any and all State laws

insofar as they may now or hereafter relate to any

2 Koester v. Estate of Koester, 101 Nev. 68, 72, 693 P.2d

569, 572 (1985).

oe | 2

60a

employee benefit plan.”4 ERISA also prohibits

alienation of benefits other than to the designated

participant or survivor’. beneficiary.6 The

Retirement Equity Act of 1984 provides an

exception to the anti-alienation provisions of

ERISA by allowing designation of an alternate

payee through the issuance of a QDRO.& The

statute defines a QDRO, in relevant part, as a

domestic relations order “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.”’

The pension plang offered by Lupe's employers

were required by ERISA to offer married employees

survivor benefits.2 One of ERISA's provides that

the joint and survivor annuity form of benefit can

be waived by the participant, Lupe, with the

spouse's written consent in the 90-day period prior

4 29 Us. § 1144(a) (Lexis 1998): see also Villescas

CNS Ins. Co., 109 Nev. 1075, 1080, 864 P.2d 288, 292 (1993);

Marcoz v. Summa Corporation, 106 Nev. 737, 748, 801 P.2d

1346, 1350 (1990).

29 U.S.C.S. § 1056(d)(1) (Lexis 1998)

6 29US.CS. § 1056(d)(3).

7 929US.CS. § 1056(d)(3)(B)(i)().

8 29 U.S.C.S. § 1055(a)(1) & (b)(1) (Lexis 1998); see also

Ronald J. Cooke, ERISA Practice and Procedure § 4:44, 4-174

(2d ed.2002).

bla

to the retirement date. Here, Lupe retired and

began receiving payments from his pensions in

1992, at which time he was still married to Janis.

Therefore, it is Janis's contention that the survivor

benefits irrevocably vested in her as Lupe's named

beneficiary upon the date of his retirement.

Judy responds that Janis waived her survivor

beneficiary benefits in the divorce decree. Federal

courts disagree as to whether ERISA authorizes a

claim of waiver, but a majority of federal circuits

have concluded that “ERISA does not preempt an

explicit waiver of interest by a nonparticipant

beneficiary” of KE RISA-regulated benefits. !°

Common law is employed to effectuate the clear

intent of the parties as to who is the beneficiary.!!

“[W]ho is entitled to the proceeds of an ERISA plan

may depend upon more than merely the plan

documents, and may be _ properly defined by

reference to ... the particular facts of the case.”!”

In this case, the district court found that Janis

agreed in the divorce action that Lupe would

receive the entirety of his retirement plans upon

paying her $1,500. Once Lupe paid Janis the

9 29 LJ S r § LO55i(c)

10 Melton v. Melton, 324 F.3d 941, 945 (7th Cir.2003); see

also Manning v. Hayes, 212 F.3d 866, S71 (5th Cir.2000), cert

denied. 532 U.S. 941 (2001)

1! Manning, 212 F.3d at 871; Silber v. Silber, 786 N.E.2d

1263, 1268 (N.Y.2003)

i2 Id

62a

$1,500, she had no more interest in his retirement

plans, including the survivor benefits. The district

court found that the survivor benefits were not an

omitted asset in the divorce decree, but were

contemplated by the parties and that each received

the total benefit package of their respective pension

plans. The district court's findings are supported by

substantial evidence. Since the pension plan

administrators would not recognize Lupe's change

of beneficiary and payments were being made to

Janis, the district court ordered that Janis hold the

proceeds received in constructive trust for Judy

Janis also argues that the imposition of a

constructive trust relating to an employee benefit

plan is preempted by ERISA. However, ERISA does

not preclude the imposition of a constructive trust

after benefits are distributed to a_ beneficiary

according to the pension plan.'' Additionally, we

agree with the Hawai Supreme Court that ERISA

does not govern our interpretation of the divorce

decree

‘3. Central States, SK & SW Areas Pension Howell, 22

I 3d 672, 678-79 (6th Cir.2000) (holding that a constructi,

trust could be imposed on employee welfare plan benefit

after distribution to beneficiary). The anti-ahenation clause

does “not protect private pension benefits once paid to and

received by the beneficiary.” Guidry v. Sheet Metal Workers

Nat. Pension Fund, 39 F.3d 1078, 1081 (10th Cir.1994): see

also Emard v. Hughes Aircraft Co., 153 F.3d 949, 955 (9th

Cir.1998), overruled on other grounds by Egelhoff v. Egelhof/

532 U.S. 141, 146, 151-52 (2001)

63a

The resolution of competing claims involving

such matters as alimony, child support, and

property (including pension interests)

accrued during a marriage is entirely with

the province of state domestic relations law

ERISA's ‘qualification’ of such domestic

relations orders is concerned solely with

enabling the plan to fulfill its fiduciary

duties by ensuring that its obligations are

clear and its liabilities are kept within the

bounds of its contract and federal law.'4

A constructive trust may be imposed if: “(Ja

confidential relationship exists between the parties:

(2) retention of legal title by the holder thereof

against another would be inequitable; and (3) the

existence of such a trust 1s essential to the

effectuation of justice.”!® In this case, there was a

confidential relationship between Janis and Lup:

as they were previously married and Jams was

designated as Lupe's survivor beneficiary. ‘Th

district court found that Janis's retention of the

pension benefits would be inequitable since Lupe

was no longer married to Janis at the time of hi:

death, and he specifically requested that Judy be

named beneficiary of his survivor benefits. The

pension plan administrators would not change the

beneficiary because of formal plan requirements. A

constructive trust is essential to effectuate the

Torre lorre 60 P d 79 817 (Haw 2002

Loc hey mit Lor hee rl, Yrs Nev 309. i 650 ? Z0 0.3 405

(1982)

64a

wishes of the plan participant. The district. court's

imposition of a constructive trust was proper

Janis disputes the district court's award. of

attorney fees of $15,000 to Judy as arbitrary and

lacking a= statutory basis. Pursuant to NERS

125.150(3), a district court has wide discretion in

awarding attorney fees in an action for divorce

when such fees are raised in the pleadings, and its

determination will-not be disturbed upon appeal

absent abuse.'© We have previously concluded tha

the district court has discretion to award attorney

fees in post-divorce proceedings.'? Upon a review of

the various and = extensive’ proceedings, we

determine that the district court did not abuse its

discretion in granting attorney fees

We ORDER the judgment of the district court

AFFIRMED.

1b furr uv. Burr, 96 Nev. 480, 482, 611 P.2d 623, 624

(1980)

17 Jlalbrook v. Halbrook, 114 Nev. 1455, 1460-61, 971

P 2d 1262, 1266 (1998)

Oba

APPIENDIX D

UNITED STATES COURT OF APPEALS

FOR THE NINTH CIRCUIT

Nos. 06-15581, 06-15938

JANIS CARMONA,

Plaintiff, |

JUDY CARMONA: HILTON HOTELS CORPORATION.

RETIREMENT PLAN,

Defendants, |

NEVADA RESORT ASSOCIATION INTERNATIONAL

ALLIANCE OF THEATRICAL AND STATE IESMPLOYEES

LOCAL, 720 PENSION ‘TRUST (1L.A.T.S.E. TRUSTEES),

Cross-Claimant-Appellant,

JUDY CARMONA, SUCCESSOR REPRESENTATIVE OF

LUPE N. CARMONA DECEASED.

Cross-Defendant-Appellee.

OG6a

JANIS CARMONA, A.K.A. JANIS KESTER.

|

|

Plaintif{f-Appellant, |

}

JUDY CARMONA, SUCCESSOR REPRESENTATIVE OF

LUPE N. CARMONA DECEASED: LLTON HOTELS

CORPORATION, RETIREMENT PLAN, |

Defendants-Appellees. |

september 10, 2010

Before: Hawkins. Thomas. and Clifton,

Circuit Judges

ORDER

The panel has voted to deny (1) Cross

defendant-Appellee Judy Carmona's Petition for

Rehearing Kn Banc, filed May 17, 2010, and (2)

Plaintiff-Petitioner Janis Carmona's Petition for

Panel Rehearing and for Rehearing En Banc, filed

June 16, 2010. Judges Thomas and Clifton have

voled to deny the petitions for rehearing en banc;

and Judge Hawkins so recommends.

The full court has been advised of the petitions

for rehearing en banc and no judge of the court has

requested a vote on whether to rehear the matter

en banc. Fed. R. App. P. 35.

The petition for rehearing and the petitions for

rehearing en banc are DENIED.

Ola

The Motion for Leave to File Amicus Curiae

Brief Supporting Appellee's Petition for Rehearing

or Rehearing En Bane and Motion to Extend the

Time of to File Amicus Curiae Brief, filed August

20, 2010, is DENIED

APPENDIX E

UNITED STATES COURT OF APPEALS

FOR THE NINTH CIRCUIT

Nos. 06-15581, 06-159388

JANIS CARMONA,

Plainttff,

JUDY CARMONA: HILTON HOTELS CORPORATION,

RETIREMENT PLAN,

Defendants,

NEVADA RESORT ASSOCIATION INTERNATIONAL

ALLIANCE OF THEATRICAL AND STATE EMPLOYEES

LOCAL 720 PENSION TRUST (L.A.T.S.E. TRUSTEES),

Cross-Claimant- Appellant,

JUDY CARMONA, SUCCESSOR REPRESENTATIVE OF

LUPE N. CARMONA DECEASED,

Cross-Defendant-Appellee.

69a

JANIS CARMONA, A.K.A. JANIS KESTER

Plaintiff-Appellant,

JUDY CARMONA, SUCCESSOR REPRESENTATIVE OF

LUPE N. CARMONA DECEASED: HILTON HOTELS

CORPORATION, RETIREMENT PLAN,

Defendants-Appellees.

September 21, 2010

Before: Hawkins, Thomas, and Clifton,

Circuit Judges

ORDER

The motion for stay of mandate pending filing of

a petition for certiorari, filed on behalf of Janis

Carmona on September 16, 2010, is GRANTED.

Pursuant to Fed. R. App. P. 41(d)(2)(B), the stay

will not extend more than 90 days from the date of

denial of the petition for rehearing unless the

period is extended for good cause or unless the

party who obtained the stay files a petition for the

writ and so notifies the Clerk of this court in

writing within the period of the stay. In that case,

the stay continues until the Supreme Court’s final

disposition.

70a

APPENDIX F

DISTRICT COURT

CLARK COUNTY, NEVADA

No. D181580

LUPE CARMONA,

Plaintiff,

V.

JANIS CARMONA,

Respondent.

October 27, 1994

COMPLAINT FOR DIVORCE

COMES NOW Plaintiff, LUPE N. CARMONA,

by and through his counsel, GERALD F. NEAL,

ESQ., and for cause of action states:

Tila

For more than six (6) weeks preceding the

commencement of this action, Plaintiff has been,

and now is, an actual and bona fide resident and

domiciliary of the State of Nevada.

IT.

Plaintiff and Defendant were intermarried in

the City of Las Vegas, State of Nevada, on or about

the 7th day of March 1988, and ever since have

been, and now are, husband and wife.

IIT.

That there are no minor children born the issue

of said marriage; there are no adopted children;

and to the best of Plaintiffs knowledge, Defendant

is not pregnant at this time.

IV.

That there is community property of the parties

hereto consisting of but not. limited to the following:

(a) 1989 Toyota Cressida automobile to which

there are no encumbrances;

(b) 1990 Toyota 4x4 V-6 Pick Up Truck with

encumbrances thereon;

V.

That there is sole and separate property of the

Plaintiff described as follows:

79,

(La

(a) The family residence situated at 7928

Wishing Well Road, Las Vegas, Nevada 89123, with

encumbrance thereon;

(b) The residence situated at 4208 Sheppard

Drive, Las Vegas, Nevada 89121, with

encumbrance thereon;

(c) The residence situated at 2115 San Simeon

Street, Las Vegas, Nevada 89108, with

encumbrance thereon:

(d) The residence situated at 204 Potential

Drive, Hollister, Missouri, with encumbrance

thereon:

(e) 1978 Chevy 4x4 Pick Up Truck to which

there are no encumbrances;

(f) Social Security Benefits;

(¢) Pension through the Hilton Hotels;

(h) Pension through the Carpenter's Union;

Gi) L.A.S.T.E. Pension;

(j) Any and all shares of stock through Merrill

Lynch;

(k) Any and all shares of stock through Ozark

Mountain Bank.

T3a

VI.

That there is community debts of the parties

hereto consisting of but not limited to the following

to be awarded to Plaintiff as his sole and separate

obligations holding Defendant harmless there from:

(a) Dovenmuehle Mortgage Company, account #

158707-0, approximate balance of $19,841.44 as

and for the lst mortgage on the family residence

situated at 7928 Wishing Well Road, Las Vegas,

Nevada 89123:

(b) I1.A.S.T.E. Mortgage Company, account #

452003, approximate balance of $5,450.57 as and

for the 2nd mortgage on the family residence

situated at 7928 Wishing Well Road, Las Vegas,

Nevada 89123:

(c) Metmor Financial, Inc., account # 931635-7,

approximate balance of $62,393.55 as and for the

mortgage on the residence situated at 4208

Sheppard Drive, Las Vegas, Nevada 89121;

(d) IFT ResidentiaV/Capital Servicing, Inc.,

account # 5486085, approximate — balance

$50,582.46 as and for the residence situated at

2115 San Simeon Street, Las Vegas, Nevada 89108;

(d) Ozark Mountain Bank, account # 002011369,

approximate balance of $108,567.95 as and for the

mortgage on the residence situated at 204 Potential

Drive, Hollister, Missouri.

(e) I.A.S.T.E., account # 1198001, approximate

balance of $4.093.10 as and for the obligation on

the 1990 Toyota 4x4 V-6 Pick Up Truck.

l4a

Vil.

That any debt incurred by either party from and

after the date of separation of the parties being

October 26, 1994, shall be the sole and separate

debt of the party incurring that debt, and each

party shall hold the other harmless from any such

debt.

VILL.

That the parties hereto are incompatible in

marriage.

WHEREFORE, Plaintiff prays for judgment

against Defendant as follows:

1. That the bonds of matrimony now and

heretofore existing between the Plaintiff and

Defendant be dissolved, and that the Plaintiff be

granted an absolute Decree of Divorce and that

each of the parties hereto be restored to the status

of a single unmarried person.

2. That the court enter an order dividing the

community property of the parties in an equitable

manner as follows:

To Plaintiff:

(a) 1990 Toyota 4x4 V-6 Pick Up Truck with

encumbrances thereon;

(b) Personal items and effects now in Plaintiffs

possession.

To Defendant:

(a) 1989 Toyota Cressida automobile to which

there is no encumbrances;

(b) Personal items and effects not in Defendant’s

possession.

2. That this Court confirm Plaintiffs sole and

separate property as set forth in the complaint

hereinabove.

3. That Plaintiff assume the community debts of

the parties as set forth in the complaint

hereinabove holding Defendant harmless

therefrom.

4. That any debt incurred by either party from

and after the date of separation of the parties being

October 26, 1994, shall be the sole and separate

debt of the party incurring that debt, and that each

party shall hold the other harmless from any such

debt.

5. For Such other and further relief as the Court

may deem just and proper.

GERALD F. NEAL, ESQUIRE

| | RS eter

GERALD F. NEAL, ESQ.

Bar No. 000353

P.O. Box 93118-98

Las Vegas, Nevada 89183-3118

ATTORNEY FOR PLAINTIFF

76a

APPENDIX G

DISTRICT COURT

CLARK COUNTY, NEVADA

No. D181580

LUPE N. CARMONA

Plaintiff,

JANIS CARMONA, |

Defendant

JANIS CARMONA.

|

Counterclaimant, |

|

LUPE N. CARMONA

Counterdefendant. |

November 23, 1994

lla

ANSWER TO COMPLAINT FOR DIVORCE

AND COUNTERCLAIM

COMES NOW, the Defendant/Counterclaimant,

JANIS CARMONA, (hereinafter referred to as

Defendant) by and through her attorney PETER J.

BELLON, ESQ., and answers the

Plaintiff/Counterdefendant's (hereinafter referred

to as Plaintiff) Complaint and makes _ her

Counterclaim for divorce as follows:

I.

Defendant admits each and every allegation in

Paragraphs I, II, and III of Plaintiff's Complaint for

Divorce.

IT.

Defendant denies Paragraphs V, VII and VIII of

Plaintiff's Complaint for Divorce

ITT.

Defendant admits to the allegation that there is

community property of the Parties but denies each

and every ether allegation contained in Paragraph

[V of Plaintiff's Complaint.

[V.

Defendant herein admits that there are

community debts of the Parties but denies each and

every other allegations contained in Paragraph VI

of Plaintiff's Complaint.

T8a

COUNTERCLAIM

COMES NOW, Counterclaimant, JANIS

CARMONA, and for her claim for relief against the

Counterdefendant, LUPE N. CARMONA, alleges a:

follows

That the Counterclaimant, JANIS CARMONA

is, and for more than six weeks immediately prior

to the filing of this action been, an actual, bona fide

resident and. domiciliary of the County of Clark,

State of Nevada, actually, physically and corporally

present and residing and being domiciled therein

during all of said period

That the Counterclaimant, JANIS CARMONA

and Counterdefendant, LUPE N. CARMONA

intermarried at I.as Vegas, Nevada on the 7th day

of March, 1988, and ever since said date have been

and now are husband and wife

IT]

That there are no minor children born the issue

of this marriage; no children were adopted during

the course of this marriage and to the best of her

knowledge Counterclaimant is not pregnant at thi:

Lime

79a

IV.

rT. - . ~

That there is community property of the parties

hereto that need be adjudicated by the Court,

including, but not limited to, the following:

|. 1989 Cressida automobile:

2. 1990 Toyota 4X4 V-6 Pickup Truck, subject to

encumbrances;

3. 1978 Chevy 4X4 Pickup Truck;

4. Community interest in the equity in the

property located at 7928 Wishing Well Road, Las

Vegas, Nevada, 89123, subject to encumbrances;

©. Community interest in the equity in the

property located at 4208 Sheppard Drive, Las

Vegas, Nevada, 89121, subject to encumbrances:

6. Real property located at 2115 San Simeon

Street, Las Vegas, Nevada, 89108, subject to

encumbrances:

7. Real property located at 204 Potential Drive,

Hollister, Missouri, subject to encumbrances:

8. Plaintiffs pension through the Hilton Hotel,

9. Any and all shares of stock through Merril

Lynch;

10. Any and all shares of stock through Ozark

Mountain Bank;

11. Plaintiff's 1.A.S.T.I. Pension:

8Oa

12. Household furniture and furnishings located

in the Hollister, Missouri, residence; and

13. Proceeds from the U.S. Gypsum Lawsuit

That Plaintiff believes that a fair and equitable

division of the community property 1s as follows

Plaintiff 1s to receive as her sole and separate

property the following items

1. 1989 Cressida automobile

One-half of the community interest in the

equity in the property located at 7928 Wishing Well

Koad, Las Vegas, Nevada, 89123, subject to

encumbrance

3. One-half of the community interest ip the

equity in the property located at 4208 Sheppard

Drive, Las Vegas, Nevada, 89121 ubject to

encumbrances

4. One-half the equity in the real property

located at 2115 San Simeon Street, Las Vegas,

Nevada, 89108, subject to encumbrances;

5. One-half the equity in the real property

located at 204 Potential Drive, Hollister, Missouri,

subject to encumbrances;

6. Pro Rata share of Plaintiffs pension through

the Hilton Hotel;

Sla

7. Pro Rata share of Plaintiff's LAST IE

Pension;

8. One-half of any and all shares of stock

through Merril Lynch;

9. One-half of any and all shares of stock

through Ozark Mountain Bank:

10. One-half of the furniture and furnishings

located in the Hollister, Missouri, residence; and

} ¢

11. Pro Rata share of the proceeds from the U.S

Gypsum [.awsuit.

Defendant is to receive as his sole and separate

property the following items:

1. 1990 ‘Toyota 4X$ v-6 Pickup Truck, subject to

encumbrances:

hb -

L\~

1978 Chevy 4X4 Pickup Truck;

3. Remaining equity in the property located at

7928 Wishing Well Road, Las Vegas, Nevada

89123, subject to encumbrances;

4. Remaining equity in the property located at

4208 Sheppard Drive, Las Vegas, Nevada, 89121,

subject to encumbrances;

5. One-half the equity in the real property

located at 2115 San Simeon Street, Las Vegas,

Nevada, 89108, subject to encumbrances;

82a

6. One-half the equity in the real property

located at 204 Potential Drive, Hollister, Missouri,

subject to encumbrances;

7. Remainder of his pension through the Hilton

Hotel:

8. Remainder of his 1.A.S.T.E. Pension:

9. One-half of any and all shares of stock

through Merril Lynch;

10. One-half of any and all shares of stock

through Ozark Mountain Bank;

11. One-half of the furniture and furnishings

located in the Hollister, Missouri, residence: and

12. Remainder of the proceeds from the U.S.

Gypsum Lawsuit

VI

That there are community debts of the parties

hereto that need be adjudicated by the Court

including, but not limited to, the following

1. Dovenmuehle Mortgage Company, Account

#158707-0, approximate balance of -$19,841.44;

2. LAS.T.E. Mortgage Company, Account

#452003, approximate balance of $5,450.57;

3. Metmor Financial, Inc., Account #931635-7.

?

approximate balance of $62,393.55;

83a

4. ITT Residential/Capital Servicing, Inc.,

Account #5486085, approximate’ balance of

$50,582.46:

5. Ozark Mountain Bank, Account #002011369,

approximate balance of $108,567.95;

6. LAS.T.E. Account #1198001, approximate

balance of $4,093. 10;

7. Various credit cards including but not limited

to the following:

(a) Dillards;

(b) First Interstate Bank Mastercard:

(c) Sears;

(d) J.C Penneys;

(ce) Texaco card;

(f) First Interstate Bank Visa;

(z) Union Privilege Mastercard;

Vil

There exists between Counterclaimant, JANIS

CARMONA, and Counterdefendant, LUPE N.

CARMONA, conflicts in_ personalities and

dispositions which are so deep as_ to. be

irreconcilable and irremediable, and which render

it impossible for the parties to continue to live

together in a normal marital relationship as

husband and wife; and therefore, the

84a

Counterclaimant and Counterdefendant have

become, and continue to be, incompatible in

marriage.

VIII.

That Counterclaimant desires that her maiden

name of Kester be restored to her.

IX.

That iS has become necessary for

Counterclaimant to engage the services of an

attorney to prosecute this action; and therefore

Counterclaimant is entitled to recover reasonable

attorney's fees, together with costs of suit.

WHEREFORE, Counterclaimant, JANIS

CARMONA, prays judgment as follows:

1. That the bonds of matrimony heretofore and

now existing between Counterclaimant and

Counterdefendant be dissolved; that the

Counterclaimant be granted an absolute decree of

divorce and that each of the parties hereto be

restored to the status of a single, unmarried

person;

2. That the Court make an equitable division of

the community property of the parties as' described

above;

3. That the Court make an equitable division of

the community debts and obligations of the parties:

4. That Counterclaimant's maiden name of

Kester be restored to her.

85a

5. That the Counterclaimant be awarded

reasonable attorney's fees, costs and allowances for

prosecution of this action; and

6. For such other and further relief as the Court

may deem meet and proper.

The Law Office of

Peter J. Bellon, Esq.

By: __ s/ /

PETER J. BIEELLON, ESQ

Nevada Bar No. 004528

804 South Sixth Street

Las Vegas, Nevada 89101

Attorney for Counterclaimant

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

A word about cookies

We need a few to keep you signed in and the library working. The rest help us see which pages people use and where they get stuck. They stay off unless you say yes.