The Owens v. Automotive Machinists Pension Trust case below raises of question of whether the Ninth Circuit would recognize same sex married partners for purposes of dividing a qualified retirment plan in a divorce. If a same sex married partner, or former married partner, may be considered a "dependent" for purposes of meeting the definition of an Alternate Payee, perhaps a same sex married (or former married partner) would also be entitled to benefits pursuant to a QDRO in a partnership dissolution.
Owens v. Automotive Machinists Pension Trust, 551 F.3d 1138 (9th Cir. 2009). http://www.ca9.uscourts.gov/datastore/opinions/2009/01/12/0735253.pdf
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