In Gonzalez v. Gonzalez, 689 S.W.2d 383, 386 (Mo. App. 1985), the court held that an award distributed under FELA was marital property subject to division. Gonzalez rationalized that the Missouri courts could divide FELA benefits in divorce actions "because Congress has not 'positively required by direct enactment' in the F.E.L.A. statutes that state law relating to a division of property in a dissolution of marriage action be preempted." 689 S.W.2d at 386.