I'm not sure that I understand the question, but I'll try to answer, and if I misunderstand, please clarify and I'll adjust my answer accordingly.
Let's say that the divorce judgment found that H had a $100,000 retirement plan from his employer. W had the option of taking $50,000 at divorce, or waiting until H retired and then taking 50% of the benefit available at that time. W chose to take the $50,000 option (called a lump-sum distribution). W would have no right to H's 50%, because that would be his share of the community property
If W elected to wait until H's retirement, and it turned out to be worth $200,000, then W would have received $100,000. But, H's retirement could have also fallen to $25,000, and if it did, then W would only receive $12,500. So, there would be a risk and a benefit to waiting -- which would be unpredictable in advance.
Given the above example, if W has already received her 50% of the retirement, then she has no claim on H's remaining retirement -- no matter how much appreciation has occurred.
Please let me know if I can be of further assistance.