Raymond Boulds, Appellant v. Elena Nielsen, Appellee

Summary

The Alaska Supreme Court affirmed the superior court’s determination that Elena Nielsen is entitled to half of Raymond Boulds’s union pension. The Court held that ERISA does not preclude division of the pension to a non‑spouse, that Alaska law provides Nielsen with the status of an “other dependent” qualifying her as an alternate payee, and that the superior court correctly applied the Bishop factors to find the parties intended the pension to be partnership property.