In 1984, the State Court of Appeals heard the case Majauskas v. Majauskas, a divorce case which concerned pension plan distribution. The plaintiff argued that his pension rights were not marital property because he began work for the Rochester Police Department before the marriage. He was vested in the pension plan when the marriage ended, but was not yet entitled to benefits. His ex-spouse believed she was entitled to a portion of the pension which was accrued during the marriage. The Appeals Court agreed with her. Out of the ruling came what is now called the Majauskas formula.