In Neville v. Neville, Ohio St.3d 275, 2003 Ohio 3624, 791 N.E.2d 434, the Ohio Supreme Court held that "in making an equitable distribution of property in a divorce proceeding, a trial court may consider the parties' future social security benefits in relation to all marital assets." The Ohio Supreme Court, however, did not define what the term "social security benefits" actually means. In Neville, the Ohio Supreme Court discussed social-security benefits as a factor in dividing property. The court held that retirement benefits accumulated during the marriage are marital property subject to division. Neville, supra, at P6. But the court acknowledged that the benefits themselves cannot be physically divided between the parties due to provisions of federal law. Id. at P7-8. The court then discussed several approaches for considering the benefits in dividing property and concluded that the most reasoned approach permits the trial court to utilize its discretion to offset the benefits against any marital property, not only against defined-benefit plans or other retirement plans. Id. at P8-10. The court upheld the trial court's adoption of a magistrate's recommendation that the wife be awarded equity in the marital residence, "explicitly balancing its value against [the husband's] social security benefits." Id. at P2 and P12.