Coulon v. Coulon

A qualified domestic relations order (hereinafter QDRO) entered pursuant to a stipulation of settlement “can convey only those rights to which the parties stipulated as a basis for the judgment” (McCoy v Feinman, 99 NY2d 295, 304 [2002]). Thus, a court cannot issue a QDRO more expansive or “encompassing rights not provided in the underlying stipulation” (id.; see Von Buren v Von Buren, 252 AD2d 950, 950-951 [1998]; De Gaust v De Gaust, 237 AD2d 862, 863 [1997]).

Here, the parties’ 1992 stipulation of settlement, which was incorporated but not merged in their judgment of divorce, provides for…