Section 15.23 Disability Benefits and Workers’ Compensation Awards
| Library | Family Law Deskbook and 2014 Supp |
G. (§15.23) Disability Benefits and Workers’ Compensation Awards
Application of the Mistler v. Mistler, 816 S.W.2d 241, 246 (Mo. App. S.D. 1991), “analytic approach” described in §15.21 above led to disability insurance benefits being considered substitutes for lost earnings occasioned by an inability to work and, therefore, the same as postdissolution earnings. As a result, they are nonmarital property under § 452.330.2(3), RSMo 2000. Sherman v. Sherman, 740 S.W.2d 203 (Mo. App. W.D. 1987). A lump-sum...
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