Miller v. Miller
In Miller v. Miller, 140 Ariz. 520, 683 P.2d 319 (App. 1984), neither party presented evidence of the present cash value of the employee spouse's retirement plan at the time of the dissolution of their marriage; the only evidence was the refund balance on an earlier date.
The Court found no abuse of the superior court's discretion in applying the reserved-jurisdiction method to divide the husband's retirement plan given that neither party had offered any evidence of the present cash value of the plan on the date of dissolution. Id. at 523, 683 P.2d at 322.