Ruth Ann Sadler v. Barbara Lois Van Buskirk

Summary

The court held that the former wife's express waiver of any interest in the former husband's retirement accounts in their property settlement agreement extinguished her claim to his IRA despite her continued beneficiary designation. Because IRA assets are owned by the account holder during life and transfer in kind at death, the agreement's specific reference to retirement accounts clearly and unambiguously included the beneficiary interest. The court reversed and remanded for a declaration that the former wife had no interest in the IRA.