context: Moreover, even greater lenience is due to domestic relations orders which were drafted prior to the REA.
citation_a.signal: see also
citation_a.identifier: 1994 WL 224352, at *5
citation_a.parenthetical: noting practice of finding QDRO despite absence of technical requirements for DROs entered before enactment of REA
citation_a.sentence: See Metropolitan Life v. Marsh, 119 F.3d 415, 422 (6th Cir.1997) (“As the divorce decree was written before the REA amended ERISA in 1984, we should not demand literal compliance where Congress’ intent has been to give effect to domestic relations orders where it is clear what the decree intended.”); Cummings by Techmeier v. Briggs & Stratton Retirement Plan, 797 F.2d 383, 388-89 (7th Cir.1986), cert. denied, 479 U.S. 1008, 107 S.Ct. 648, 93 L.Ed.2d 703 (1986); see also Layton v. TDS Healthcare Sys. Corp., No. C-93-1827-MHP, 1994 WL 224352, at *5 (N.D.Cal. May 17, 1994) (noting practice of finding QDRO despite absence of technical requirements for DROs entered before enactment of REA).
citation_b.signal: see
citation_b.identifier: 119 F.3d 415, 422
citation_b.parenthetical: "As the divorce decree was written before the REA amended ERISA in 1984, we should not demand literal compliance where Congress' intent has been to give effect to domestic relations orders where it is clear what the decree intended."
citation_b.sentence: See Metropolitan Life v. Marsh, 119 F.3d 415, 422 (6th Cir.1997) (“As the divorce decree was written before the REA amended ERISA in 1984, we should not demand literal compliance where Congress’ intent has been to give effect to domestic relations orders where it is clear what the decree intended.”); Cummings by Techmeier v. Briggs & Stratton Retirement Plan, 797 F.2d 383, 388-89 (7th Cir.1986), cert. denied, 479 U.S. 1008, 107 S.Ct. 648, 93 L.Ed.2d 703 (1986); see also Layton v. TDS Healthcare Sys. Corp., No. C-93-1827-MHP, 1994 WL 224352, at *5 (N.D.Cal. May 17, 1994) (noting practice of finding QDRO despite absence of technical requirements for DROs entered before enactment of REA).