In In re Marriage of Havins (1996) 43 Cal. App. 4th 414, the husband was already retired and receiving pension benefits at the time of the divorce. The dissolution judgment provided that his pension be divided equally between the parties. The underlying dispute involved whether the payment of premiums for each party's health care coverage was to be taken off the top from the gross pension, or each party would pay the premium for his or her own coverage out of the portion distributed to them. (In re Marriage of Havins, supra, 43 Cal. App. 4th 414, 416-417.) This made a practical difference because the husband's premiums were subsidized by the former employer, whereas the wife's premiums were for the full cost for nongroup, individual coverage. (Id. at p. 418, fn. 1.) When the trial court ruled that taking the premiums off the top would unfairly require the husband to pay a portion of the higher cost of the wife's coverage, the wife sought to avoid this result by arguing that the husband's "right to purchase subsidized health insurance" was a community asset in which she could share. (Id. at pp. 417-418.) Deciding the issue as a question of first impression (In re Marriage of Havins, supra, 43 Cal. App. 4th at p. 418), the appellate court held that even though "employer-subsidized retiree health insurance is unquestionably a fringe benefit derived from employment," and the husband had "earned the right to have and renew such insurance by his long-term employment," and this right was "itself a property right that has some value," nevertheless this property right may not be divided as community property. (Id. at pp. 423-424.) Lacking prior precedent directly on point, the court analogized to various cases involving the postseparation purchase of renewable term life insurance and renewable term disability insurance. (Id. at pp. 418-422.) Those precedents offered the court several possible rationales for its holding: the right to subsidized health insurance is not convertible to cash; some fringe benefits of undisputed value to the employee or retiree are simply not divisible for the benefit of the spouse upon divorce (e.g., a right to a discount at an employer-owned cafeteria or store); and after divorce each renewal for a new term occurs outside the marriage and, to the extent additional premiums are required, the premiums come from the separate property of the employee or retiree. (Ibid.)