In Irato v. Irato (288 AD2d 952), the Court struck down a QDRO on the ground that it deviated from the judgment of divorce. The QDRO awarded the defendant a survivor annuity, while no provision for such an award was made in the judgment of divorce. The Appellate Division reasoned that the issue of equitable distribution was fully litigated at the time of the divorce, and held that a final judgment of divorce issued by a court having both subject matter and personal jurisdiction has the effect of determining the rights of the parties with respect to every material issue that was actually litigated, or might have been litigated.