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9th Circuit Decides QJSA Tug of War in Favor of Spouse at Time of Retirement
The Pension Protection Act Blog 
[Guidance Overview] Sept. 22, 2008
Excerpt: [T]he 9th Circuit Court of Appeals decided whether or not a participant in a plan with a Qualified Joint and Survivor Annuity (QJSA) may change the surviving spouse beneficiary after the participant has retired and the annuity has become payable. In Caruso v. Caruso, No. 06-15938 (CA9 Sept. 17, 2008), the Court held that the 'QJSA surviving spouse benefits irrevocably vest in the participant's spouse at the time of the annuity start date - in this case the participant's retirement - and may not be reassigned to a subsequent spouse.'
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