In Brown v. Brown, 38 Ark. App. 99, 828 S.W.2d 601 (Ark. App. 1992), The Arkansas court concluded that recipients of a fixed percentage of pension benefits enjoy post-separation increases in pension benefits, reasoning as follows:
"We find no valid reason for holding that the award of one-half of 90 percent of the gross retirement benefits does not carry with it the same portion of any cost of living adjustment ("COLA") increases or decreases that occur subsequent to the divorce." Id. at 602.
In that case, the ex-wife was awarded a portion of the ex-husband's military retirement benefits earned during marriage and was entitled to a corresponding percentage share of cost of living adjustments. Id.