In Barnett v. Barnett, 67 S.W.3d 107, 45 Tex. Sup. Ct. J. 171 (Tex. 2001), the surviving spouse's claims depended on her community property rights. Id. at 112. Because most states are not community property states, a plurality of this Court believed that our community property laws do not lend themselves "to the application of uniform federal common law" and thus interfere with uniform ERISA plan administration. Id. at 126. The plurality recognized, though, that "Congress 'intended that the courts would "develop a 'federal common law of rights and obligations under ERISA-regulated plans.'"'" Id. at 122.