retirement enhancements, because such increase was expected at the time of investment). Other jurisdictions have chosen to freeze the non-employee spouse’s share at the time of dissolution, or otherwise determined that early retirements are not subject to marital property division. Cf In re Marriage of Oddino, 16 Cal.4th 67, 65 Cal.Rptr.2d 566, 939 P.2d 1266, 1279 (1997) (stating that when the participant has not yet retired, the former spouse’s benefit under a QDRO is limited to the actuarial value of normal retirement benefits and any unreduced early retirement benefits are an employer subsidy that, under federal ERISA law, may not be ordered paid under a QDRO while the participant continues to work for the plan sponsor); Blaine v. Blaine, 872 So.2d 383, 384-85 (Fla.Dist.Ct.App.2004) (<HOLDING>); Hodowal v. Hodowal, 627 N.E.2d 869, 873
holding that qdros providing the former wife with future enhancements that were not part of the marital portion of husbands pension plan including future improvements cost of living adjustments and early retirement subsidies conflicted with the final judgment that valued the pension at the time of dissolution holding that although disability benefits cannot be included as part of the marital estate a court may consider the waiver of retirement pension benefits in favor of disability benefits in determining whether there has been a material change in circumstances which would justify modification of an alimony award to a former spouse who was previously awarded a fixed percentage of the retirement pension benefits holding that the defendant withheld pension benefits in breach of the plan holding that a nonemployee spouse holds a community marital property interest in pension plan early retirement enhancements because practically by definition the right to retirement benefits that accrues at least in part during marriage before separation underlies any right to an enhancement holding that nonemployee spouse waived distribution of her husbands early retirement benefits because although both parties were aware of the enhancements the additional benefits were not included in calculation of the pension funds at the time of dissolution