In re Marriage of Shelstead

In In re Marriage of Shelstead (1998) 66 Cal.App.4th 893, the Court concluded the QDRO was invalid under section 1056, subdivision (d)(3)(K) because that subdivision limits the persons who can qualify as an alternate payee, and the QDRO in Shelstead ordered payment to the former wife (a qualified alternate payee) or her designated "successor in interest" (a potentially nonqualified alternate payee). (Id. at pp. 902-905.)