Bodin v. Bodin
In Bodin v. Bodin, 955 S.W.2d 380, 381 (Tex. Ct. App. 1997) a Texas appellate court affirmed the trial court's ruling that unvested stock options, like military retirement benefits, were a community asset because they constituted a contingent interest in property earned during the marriage.
The Bodin court, however, did not analyze whether the unvested stock options were for past performance or incentive for future performance, or whether that purpose might limit the community's interest in the stock options to the extent the unvested options were intended as compensation for post-divorce services. Id. Although it cited Hug and other cases which considered those questions, it did not analyze them. Id.