Niroo v. Niroo
Maryland Court of Appeals
545 A.2d 35 (1988)
During his marriage to Mojgan Niroo, David Niroo worked as an insurance salesman and manager, entering an agreement during the marriage entitling him to future commissions if certain policies he sold were renewed, subject to a non-compete covenant and renewal-volume requirements; he also received loan advances from insurance companies chargeable against those future commissions. At divorce, the trial court valued his future renewal-commission interest as marital property worth $410,000 but treated $267,000 in outstanding advances as a separate economic circumstance rather than marital debt, awarding Ms. Niroo a $200,000 monetary award; Mr. Niroo appealed, arguing the commissions were too speculative and contingent to be marital property and that the advances should have reduced their value.
Whether an insurance salesman's contractual right to future renewal commissions on policies sold during the marriage constitutes marital property despite requiring continued satisfaction of renewal conditions after the marriage ends, and whether loan advances chargeable against those commissions should be deducted as marital debt.