Marriage of Jacobson

Mrs. Jacobson (plaintiff) filed for divorce in California from Mr. Jacobson (defendant), an active-duty military member domiciled in Iowa but stationed in California; after initially moving to dismiss on forum non conveniens and lack-of-consent grounds, Mr. Jacobson signed a handwritten consent decree agreeing to have the case resolved under California law, and later signed a second stipulation expressly stating the court would reserve jurisdiction over his military pension. In 1983, Mr. Jacobson became eligible for his military pension though he hadn't retired, and Mrs. Jacobson sought to divide it; Mr. Jacobson argued the trial court lacked jurisdiction to apply California law or classify his pension as community property, but the trial court made factual findings and legally divided the pension anyway. Mr. Jacobson appealed.