Fo-shay’s name, the findings of fact indicate that the 401k was actually titled in the debtor’s name. 3 . Neither party disputes that the lien securing the Judgment is a judicial lien, so that question need not be addressed. 4 . For purposes of this opinion, this Court does not question whether the Washington Supreme Court would also hold that same-sex partners can be treated in the same manner as heterosexual couples in a meretricious relationship, as was the case in Connell. In this case, the State Court made a specific finding that the parties were in a meretricious relationship and that finding is binding on this Court. It does not appear that the appellate courts in Washington have directly addressed this issue. See, e.g., Vasquez v. Hawthorne, 145 Wash.2d 103, 33 P.3d 735 (2001)(<HOLDING>). 5 . These liens have also become known
holding that excessive force claims are to be treated under the fourth amendment holding that before a duty can be imposed there must be a relationship between the parties and the harm must have been foreseeable holding that claims to property between samesex partners should be treated as equitable claims without addressing whether parties can be deemed to be in a meretricious relationship holding that general partners must notify limited partners of partnership opportunity to purchase adjacent property but not addressing whether  9404 requires affirmative consent of partners after such notice holding that claims including constitutional claims must be asserted in trial court to be raised on appeal