In Hale v. Hale, Mont. App. No. 21402, 2007 Ohio 867, the Court held that early supplemental retirement benefits that were part of a General Motors pension were properly divisible as marital property because they were earned during the marriage and in order to be excludable from the benefits divided by the QDRO, there must have been a specific exclusion of them in the settlement agreement incorporated in the decree. The Court held that when the QDRO is inconsistent with the decree, the trial court lacks jurisdiction to issue the same, and it is void.