In a Decision – Orlowski v. Orlowski, , (a "Reported Decision") >> the Court Held:
The Appellate Division determined that Husband’s failures and deficiencies required that his retirement/annuity funds be utilized to pay Husband’s obligations including counsel fees.
QDROs (Qualified Domestic Relations Orders) could be used to compensate a spouse for legal and accounting fees incurred to enforce child support or equitable distribution obligations. The court further ruled that the college tuition reimbursement was also enforceable through a QDRO as the tuition was classified as child support. Finally, the court ruled that the trial court erred by not ordering enhanced wage garnishment to pay counsel fees incurred to enforce child support.