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FAMILY COURT SHOULD NOT HAVE SUMMARILY DENIED COUNTY’S APPLICATION FOR PATERNITY DNA TESTING WITHOUT REQUIRING PUTATIVE FATHER TO RAISE A QUESTION OF FACT TO SUPPORT THE EQUITABLE ESTOPPEL DEFENSE; COUNTY HAS STATUTORY AUTHORITY TO BRING A PATERNITY ACTION WHEN THE MOTHER OR CHILD IS LIKELY TO BECOME A PUBLIC CHARGE.

The Second Department, reversing Family Court, determined Family Court should not have denied, without a hearing, the County’s request for DNA paternity testing. The putative father had not raised a question of fact to support his assertion of the equitable estoppel defense (demonstrating that another had developed a father-child relationship). Only after determining whether equitable estoppel defense applies can the propriety of DNA testing be considered. The County has the statutory authority to bring a paternity proceeding when the mother or child is likely to become a public charge:

… [A]rticle 5 of the Family Court Act still retains as an objective the protection of the public from bearing the cost of supporting . . . children where there exists a viable, legally obligated source of support” … . Accordingly, “section 522 of the Family Court Act provides that, among other persons, a public welfare official of the county, city or town where the mother resides, or the child is found, may originate such proceedings, if the mother or child is or is likely to become a public charge'” … . * * *

… [T]he doctrine of equitable estoppel may be used by a purported biological father to prevent an adverse party from asserting that he is the biological father where the child has developed a close relationship with another father figure such that it would be detrimental to the child’s interests to disrupt that relationship … . Under such circumstances, in order to be entitled to a hearing on the issue of whether equitable estoppel should be applied, a putative father must raise an issue of fact as to whether “a determination that he is in fact the father would disturb any relationship the child[ ] may have had with any other father figure” … . “[W]hether it is being used in the offensive posture to enforce rights or the defensive posture to prevent rights from being enforced, equitable estoppel is only to be used to protect the best interests of the child” … . …

The Family Court … erred to the extent that it based its order dismissing the petition on its prior determination, in effect, denying the County’s application for DNA testing. The Family Court should not have summarily denied the County’s application without first requiring the putative father to raise an issue of fact with respect to his defense of equitable estoppel … . Matter of Suffolk County Dept. of Social Servs. v James D., 2017 NY Slip Op 01369, 2nd Dept 2-22-17

 

FAMILY LAW (PATERNITY, FAMILY COURT SHOULD NOT HAVE SUMMARILY DENIED COUNTY’S APPLICATION FOR PATERNITY DNA TESTING WITHOUT REQUIRING PUTATIVE FATHER TO RAISE A QUESTION OF FACT TO SUPPORT THE EQUITABLE ESTOPPEL DEFENSE)/PATERNITY (FAMILY COURT SHOULD NOT HAVE SUMMARILY DENIED COUNTY’S APPLICATION FOR PATERNITY DNA TESTING WITHOUT REQUIRING PUTATIVE FATHER TO RAISE A QUESTION OF FACT TO SUPPORT THE EQUITABLE ESTOPPEL DEFENSE)/DNA TESTING (FAMILY LAW, PATERNITY, FAMILY COURT SHOULD NOT HAVE SUMMARILY DENIED COUNTY’S APPLICATION FOR PATERNITY DNA TESTING WITHOUT REQUIRING PUTATIVE FATHER TO RAISE A QUESTION OF FACT TO SUPPORT THE EQUITABLE ESTOPPEL DEFENSE)/FAMILY LAW (PATERNITY, COUNTY HAS THE STATUTORY AUTHORITY TO BRING A PATERNITY ACTION WHEN THE MOTHER OR CHILD IS LIKELYT TO BECOME A PUBLIC CHARGE)/PATERNITY (COUNTY HAS THE STATUTORY AUTHORITY TO BRING A PATERNITY ACTION WHEN THE MOTHER OR CHILD IS LIKELYT TO BECOME A PUBLIC CHARGE)/PUBLIC CHARGE (FAMILY LAW, PATERNITY, COUNTY HAS THE STATUTORY AUTHORITY TO BRING A PATERNITY ACTION WHEN THE MOTHER OR CHILD IS LIKELYT TO BECOME A PUBLIC CHARGE)

SUPREME COURT SHOULD HAVE ORDERED PENDENTE LITE MAINTENANCE DESPITE WAIVER OF MAINTENANCE UPON TERMINATION OF THE MARRIAGE IN THE PRENUPTIAL AGREEMENT, SUPREME COURT FAILED TO EXPLAIN THE DEVIATION FROM THE CHILD SUPPORT STANDARDS ACT IN ITS AWARD OF PENDENTE LITE CHILD SUPPORT, CASE REMITTED.

The Second Department determined a waiver of maintenance, equitable distribution and an award of attorney’s fees included in the prenuptial agreement did not preclude Supreme Court from awarding temporary relief prior to termination of the marriage. The Second Department also held that Supreme Court’s pendente lite child support deviated from the criteria of the Child Support Standards Act (CSSA) and therefore an explanation for the deviation was required:

Although the prenuptial agreement contains a waiver of maintenance, equitable distribution, and an award of attorney’s fees in the event of termination of the marriage, it does not bar temporary relief, including pendente lite maintenance and attorney’s fees during the pendency of this litigation … . While the Supreme Court properly awarded the plaintiff interim attorney’s fees, the court, without explanation, improvidently denied that branch of the plaintiff’s motion which was for an award of pendente lite maintenance. Accordingly, we remit the matter to the Supreme Court, Nassau County, for a new determination of that branch of the plaintiff’s motion … .

In determining an award of pendente lite child support, courts may, in their discretion, apply the Child Support Standards Act (hereinafter CSSA) standards and guidelines, but they are not required to do so … . “However, under some circumstances, particularly where sufficient economic data is available, an award of temporary child support that deviates from the level that would result if the provisions of the CSSA were applied may constitute an improvident exercise of discretion, absent the existence of an adequate reason for the deviation” … . Here, the court failed to provide any explanation as to how it determined the amount of the award of pendente lite child support. Under the circumstances of this case, the matter must be remitted to the Supreme Court … . Kashman v Kashman, 2017 NY Slip Op 01343, 2nd Dept 2-22-17

 

FAMILY LAW (SUPREME COURT SHOULD HAVE ORDERED PENDENTE LITE MAINTENANCE DESPITE WAIVER OF MAINTENANCE UPON TERMINATION OF THE MARRIAGE IN THE PRENUPTIAL AGREEMENT, SUPREME COURT FAILED TO EXPLAIN THE DEVIATION FROM THE CHILD SUPPORT STANDARDS ACT IN ITS AWARD OF PENDENTE LITE CHILD SUPPORT, CASE REMITTED)/PRENUPTIAL AGREEMENT (SUPREME COURT SHOULD HAVE ORDERED PENDENTE LITE MAINTENANCE DESPITE WAIVER OF MAINTENANCE UPON TERMINATION OF THE MARRIAGE IN THE PRENUPTIAL AGREEMENT, SUPREME COURT FAILED TO EXPLAIN THE DEVIATION FROM THE CHILD SUPPORT STANDARDS ACT IN ITS AWARD OF PENDENTE LITE CHILD SUPPORT, CASE REMITTED)/PENDENTE LITE MAINTENANCE (SUPREME COURT SHOULD HAVE ORDERED PENDENTE LITE MAINTENANCE DESPITE WAIVER OF MAINTENANCE UPON TERMINATION OF THE MARRIAGE IN THE PRENUPTIAL AGREEMENT, SUPREME COURT FAILED TO EXPLAIN THE DEVIATION FROM THE CHILD SUPPORT STANDARDS ACT IN ITS AWARD OF PENDENTE LITE CHILD SUPPORT, CASE REMITTED)/PENDENTE LITE CHILD SUPPORT (SUPREME COURT SHOULD HAVE ORDERED PENDENTE LITE MAINTENANCE DESPITE WAIVER OF MAINTENANCE UPON TERMINATION OF THE MARRIAGE IN THE PRENUPTIAL AGREEMENT, SUPREME COURT FAILED TO EXPLAIN THE DEVIATION FROM THE CHILD SUPPORT STANDARDS ACT IN ITS AWARD OF PENDENTE LITE CHILD SUPPORT, CASE REMITTED)/MAINTENANCE (SUPREME COURT SHOULD HAVE ORDERED PENDENTE LITE MAINTENANCE DESPITE WAIVER OF MAINTENANCE UPON TERMINATION OF THE MARRIAGE IN THE PRENUPTIAL AGREEMENT, SUPREME COURT FAILED TO EXPLAIN THE DEVIATION FROM THE CHILD SUPPORT STANDARDS ACT IN ITS AWARD OF PENDENTE LITE CHILD SUPPORT, CASE REMITTED)CHILD SUPPORT (SUPREME COURT SHOULD HAVE ORDERED PENDENTE LITE MAINTENANCE DESPITE WAIVER OF MAINTENANCE UPON TERMINATION OF THE MARRIAGE IN THE PRENUPTIAL AGREEMENT, SUPREME COURT FAILED TO EXPLAIN THE DEVIATION FROM THE CHILD SUPPORT STANDARDS ACT IN ITS AWARD OF PENDENTE LITE CHILD SUPPORT, CASE REMITTED)/CHILD SUPPORT STANDARDS ACT (CSSA) (SUPREME COURT SHOULD HAVE ORDERED PENDENTE LITE MAINTENANCE DESPITE WAIVER OF MAINTENANCE UPON TERMINATION OF THE MARRIAGE IN THE PRENUPTIAL AGREEMENT, SUPREME COURT FAILED TO EXPLAIN THE DEVIATION FROM THE CHILD SUPPORT STANDARDS ACT IN ITS AWARD OF PENDENTE LITE CHILD SUPPORT, CASE REMITTED)

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FAMILY COURT SHOULD HAVE MADE FINDINGS TO ALLOW JUVENILE TO PETITION FOR SPECIAL IMMIGRANT JUVENILE STATUS.

The Second Department determined Family Court should have granted the motion for findings to allow a juvenile to petition for special immigrant juvenile state (SIJS):

Based upon our independent factual review, we find that the record fully supports the petitioner’s contention that, because the child’s mother neglected him, reunification with the mother is not a viable option … . Contrary to the Family Court’s determination, the record demonstrated that the physical, mental, or emotional condition of the child had been impaired or was in imminent danger of becoming impaired as a result of the failure of the mother to exercise a minimum degree of care “in supplying the child with adequate food, clothing, shelter or education . . . though financially able to do so or offered financial or other reasonable means to do so” … . Indeed, the petitioner’s testimony at the hearing demonstrated that although the mother received financial assistance to provide for the child’s clothing and education, the mother failed to use such assistance for the child’s benefit. The child’s testimony corroborated the petitioner’s testimony in this respect.

Accordingly, the Family Court should have granted the petitioner’s motion for the issuance of an order making the requisite declaration and specific findings so as to enable the child to petition for SIJS. Matter of Wilson A.T.Z. (Jose M.T.G.–Manuela Z.M.), 2017 NY Slip Op 01215, 2nd Dept 2-15-17

 

FAMILY LAW (SPECIAL IMMIGRANT JUVENILE STATUS, FAMILY COURT SHOULD HAVE MADE FINDINGS TO ALLOW JUVENILE TO PETITION FOR SPECIAL IMMIGRANT JUVENILE STATUS)/IMMIGRATION LAW (SPECIAL IMMIGRANT JUVENILE STATUS, FAMILY COURT SHOULD HAVE MADE FINDINGS TO ALLOW JUVENILE TO PETITION FOR SPECIAL IMMIGRANT JUVENILE STATUS)/SPECIAL IMMIGRANT JUVENILE STATUS (SIJS) ( FAMILY COURT SHOULD HAVE MADE FINDINGS TO ALLOW JUVENILE TO PETITION FOR SPECIAL IMMIGRANT JUVENILE STATUS)

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CHILD SHOULD NOT HAVE BEEN REMOVED FROM FATHER’S CARE, EVEN THOUGH CHILD HAS BEEN RETURNED, APPEAL NOT MOOT BECAUSE OF THE STIGMA OF REMOVAL.

The Second Department, reversing Family Court, determined the removal application should not have been granted and father’s appeal of the removal was not moot, even though the child had been returned to the father:

Although it is undisputed that the child has been returned to the father’s care, the father’s appeals are not academic. The child’s removal created a permanent and significant stigma … .

“In determining a removal application pursuant to Family Court Act § 1027, the court must engage in a balancing test of the imminent risk with the best interests of the child and, where appropriate, the reasonable efforts made to avoid removal or continuing removal'” … . Here, the petitioner failed to establish that the child would be subjected to imminent risk if she were not placed in the custody of the petitioner pending the outcome of the neglect proceeding. Under the circumstances of this case, concerns about, inter alia, the adequacy of the father’s plan to care for the child did not amount to an imminent risk to the child’s life or health that could not be mitigated by reasonable efforts to avoid removal. Matter of Emmanuela B. (Jean E.B.), 2017 NY Slip Op 01195, 2nd Dept 2-15-17

 

FAMILY LAW (NEGLECT, REMOVAL, CHILD SHOULD NOT HAVE BEEN REMOVED FROM FATHER’S CARE, EVEN THOUGH CHILD HAS BEEN RETURNED, APPEAL NOT MOOT BECAUSE OF THE STIGMA OF REMOVAL)/APPEALS (FAMILY LAW, CHILD SHOULD NOT HAVE BEEN REMOVED FROM FATHER’S CARE, EVEN THOUGH CHILD HAS BEEN RETURNED, APPEAL NOT MOOT BECAUSE OF THE STIGMA OF REMOVAL)/NEGLECT (CHILD SHOULD NOT HAVE BEEN REMOVED FROM FATHER’S CARE, EVEN THOUGH CHILD HAS BEEN RETURNED, APPEAL NOT MOOT BECAUSE OF THE STIGMA OF REMOVAL)/REMOVAL (CHILD NEGLECT, FAMILY LAW, CHILD SHOULD NOT HAVE BEEN REMOVED FROM FATHER’S CARE, EVEN THOUGH CHILD HAS BEEN RETURNED, APPEAL NOT MOOT BECAUSE OF THE STIGMA OF REMOVAL)

FAMILY COURT COULD NOT ALLOW VISITATION WHILE A CRIMINAL ORDER OF PROTECTION IS IN PLACE.

The Second Department determined that Family Court properly denied mother’s motion for kinship visitation because a criminal court order of protection was in place:

As a general rule, the “Family Court does not have jurisdiction to countermand the provisions of a criminal court order of protection” … . Thus, where a criminal court order of protection bars contact between a parent and child, the parent may not obtain visitation until the order of protection is vacated or modified by the criminal court … . However, the criminal court has authority to determine whether its order of protection is “subject to” subsequent Family Court orders, and where the criminal court order of protection “expressly contemplates future amendment of its terms by a subsequent Family Court order pertaining to custody and visitation,” the Family Court is not precluded from granting custody or visitation by the terms of the order of protection … . Here, since the Supreme Court’s temporary order of protection dated April 1, 2016, did not state that it was “subject to” subsequent Family Court orders, the Family Court had no basis to permit “kinship visitation” supervised by the maternal grandmother. Matter of Rihana J.H. (Quianna J.), 2017 NY Slip Op 01202, 2nd Dept 2-15-17

FAMILY LAW (FAMILY COURT COULD NOT ALLOW VISITATION WHILE A CRIMINAL ORDER OF PROTECTION IS IN PLACE)/VISITATION (FAMILY LAW, FAMILY COURT COULD NOT ALLOW VISITATION WHILE A CRIMINAL ORDER OF PROTECTION IS IN PLACE)/CRIMINAL LAW (FAMILY LAW, ORDER OF PROTECTION, FAMILY COURT COULD NOT ALLOW VISITATION WHILE A CRIMINAL ORDER OF PROTECTION IS IN PLACE)/ORDER OF PROTECTION (FAMILY LAW,  FAMILY COURT COULD NOT ALLOW VISITATION WHILE A CRIMINAL ORDER OF PROTECTION IS IN PLACE)

FATHER SHOULD NOT HAVE BEEN AWARDED SOLE CUSTODY IN THE ABSENCE OF A HEARING.

The Second Department, reversing Supreme Court, determined father should not have been awarded sole custody without a hearing:

The Supreme Court erred in awarding the father sole custody of the child in the absence of a hearing to determine the best interests of the child. “[A] court opting to forgo a plenary hearing must take care to clearly articulate which factors were—or were not—material to its determination, and the evidence supporting its decision” … . The court failed to do so here. Furthermore, the issue of custody was not discussed at the … court appearances that resulted in the issuance of the final order of custody and visitation. Under these circumstances, the mother’s motion to vacate the final order of custody and visitation … , should have been granted. Matter of Fraser v Fleary, 2017 NY Slip Op 01197, 2nd Dept 2-15-17

FAMILY LAW (FATHER SHOULD NOT HAVE BEEN AWARDED SOLE CUSTODY IN THE ABSENCE OF A HEARING)/CUSTODY (FAMILY LAW, FATHER SHOULD NOT HAVE BEEN AWARDED SOLE CUSTODY IN THE ABSENCE OF A HEARING)

WIFE ENTITLED TO SHARE OF HUSBAND’S SEPARATE PROPERTY WHICH WAS COMMINGLED WITH MARITAL FUNDS, WIFE ALSO ENTITLED TO SHARE OF APPRECIATION OF HUSBAND’S SEPARATE PROPERTY.

The Second Department determined plaintiff wife was entitled to a share of husband’s separate property that was commingled with marital funds, as well as a share of the appreciation of husband’s separate property. Husband, a firefighter, received an award from the September 11th Victim Compensation Fund, which was placed in a joint checking account and then used to buy investment property:

… [S]eparate property that is commingled, for example, in a joint bank account, loses its character of separateness and a presumption arises that each party is entitled to a share of the funds … . “That presumption, however, may be overcome by clear and convincing evidence, either direct or circumstantial, that the account was created only as a matter of convenience” … . The presumption may also be overcome by evidence that the account, although joint, is managed solely by one party … , or that the funds were deposited into the joint account only briefly … . In this case, the Supreme Court correctly determined that by depositing the proceeds of the award into the parties’ joint account, the defendant’s separate property lost its character of separateness and a presumption arose that each party was entitled to a share of the funds, which was not rebutted. …

The record supports the Supreme Court’s determination that the direct and indirect contributions of the plaintiff, as the nontitled spouse, contributed to the appreciation in the value of the defendant’s separate properties. Therefore, the plaintiff was entitled to a share of that appreciation … . Brown v Brown, 2017 NY Slip Op 01175, 2nd Dept 2-15-17

 

FAMILY LAW (WIFE ENTITLED TO SHARE OF HUSBAND’S SEPARATE PROPERTY WHICH WAS COMMINGLED WITH MARITAL FUNDS, WIFE ALSO ENTITLED TO SHARE OF APPRECIATION OF HUSBAND’S SEPARATE PROPERTY)/SEPARATE PROPERTY (FAMILY LAW, (WIFE ENTITLED TO SHARE OF HUSBAND’S SEPARATE PROPERTY WHICH WAS COMMINGLED WITH MARITAL FUNDS, WIFE ALSO ENTITLED TO SHARE OF APPRECIATION OF HUSBAND’S SEPARATE PROPERTY)/MARITAL PROPERTY (WIFE ENTITLED TO SHARE OF HUSBAND’S SEPARATE PROPERTY WHICH WAS COMMINGLED WITH MARITAL FUNDS, WIFE ALSO ENTITLED TO SHARE OF APPRECIATION OF HUSBAND’S SEPARATE PROPERTY)

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EXPUNGEMENT NOT AVAILABLE FOR CHILD NEGLECT CASE REFERRED TO THE FAMILY ASSESSMENT RESPONSE TRACK (FAR TRACK).

The Court of Appeals, in a full-fledged opinion by Judge Fahey, determined the statutory scheme for a potential child-neglect case referred to the Family Assessment Response Track (FAR track) does not provide a mechanism for expungement. Here a potential educational neglect case was referred to the FAR track and ultimately no action was taken by the caseworker and the case was closed. The petitioners requested expungement:

Petitioners contend that the right to seek early expungement may be inferred from the silence of Social Services Law § 427-a on this topic. We disagree. Principles of statutory construction teach that “the failure of the Legislature to include a substantive, significant prescription in a statute is a strong indication that its exclusion was intended” … . Moreover, this is not a case in which the two statutes that petitioners seek to interpret in identical fashion “relate to the same subject matter, contain identical language and were adopted together” … . Rather, the FAR track was created as a new and entirely separate means of addressing certain allegations of child abuse in a program geared toward the provision of social services, rather than an investigation assessing blame. In other words, the subject matter of the FAR track cannot be deemed identical to that of a traditional child abuse investigation. Matter of Corrigan v New York State Off. of Children & Family Servs., 2017 NY Slip Op 01020, CtApp 2-9-17

FAMILY LAW (EDUCATIONAL NEGLECT, EXPUNGEMENT NOT AVAILABLE FOR CHILD NEGLECT CASE REFERRED TO THE FAMILY ASSESSMENT RESPONSE TRACK (FAR TRACK))/CHILD ABUSE (EDUCATIONAL NEGLECT, EXPUNGEMENT NOT AVAILABLE FOR CHILD NEGLECT CASE REFERRED TO THE FAMILY ASSESSMENT RESPONSE TRACK (FAR TRACK))/CHILD NEGLECT (EDUCATIONAL NEGLECT, EXPUNGEMENT NOT AVAILABLE FOR CHILD NEGLECT CASE REFERRED TO THE FAMILY ASSESSMENT RESPONSE TRACK (FAR TRACK))/EDUCATIONAL NEGLECT (EXPUNGEMENT NOT AVAILABLE FOR CHILD NEGLECT CASE REFERRED TO THE FAMILY ASSESSMENT RESPONSE TRACK (FAR TRACK))/EXPUNGEMENT (EDUCATIONAL NEGLECT, EXPUNGEMENT NOT AVAILABLE FOR CHILD NEGLECT CASE REFERRED TO THE FAMILY ASSESSMENT RESPONSE TRACK (FAR TRACK))/SOCIAL SERVICES LAW  (EDUCATIONAL NEGLECT, EXPUNGEMENT NOT AVAILABLE FOR CHILD NEGLECT CASE REFERRED TO THE FAMILY ASSESSMENT RESPONSE TRACK (FAR TRACK))/FAMILY ASSESSMENT RESPONSE TRACT (FAR TRACK) (EDUCATIONAL NEGLECT, EXPUNGEMENT NOT AVAILABLE FOR CHILD NEGLECT CASE REFERRED TO THE FAMILY ASSESSMENT RESPONSE TRACK (FAR TRACK))

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MOTION FOR FINDINGS ALLOWING CHILD TO PETITION FOR SPECIAL IMMIGRANT JUVENILE STATUS SHOULD HAVE BEEN GRANTED.

The Second Department determined Family Court should have granted the child’s motion for findings to allow him to petition for special immigrant juvenile status:

Pursuant to 8 USC § 1101(a)(27)(J) … and 8 CFR 204.11, a special immigrant is a resident alien who, inter alia, is under 21 years of age, unmarried, and dependent upon a juvenile court or legally committed to an individual appointed by a state or juvenile court. Additionally, for a juvenile to qualify for SIJS, a court must find that reunification of the juvenile with one or both of the juvenile’s parents is not viable due to parental abuse, neglect, abandonment, or a similar basis found under state law … , and that it would not be in the juvenile’s best interests to be returned to his or her previous country of nationality or country of last habitual residence … .

Based upon our independent factual review, we find that reunification of the child with one or both of his parents is not a viable option due to parental abandonment … , and that it would not be in his best interests to return to India … . Matter of Varinder S. v Satwinder S., 2017 NY Slip Op 00987, 2nd Dept 2-8-17

 

FAMILY LAW (MOTION FOR FINDINGS ALLOWING CHILD TO PETITION FOR SPECIAL IMMIGRANT JUVENILE STATUS SHOULD HAVE BEEN GRANTED)/IMMIGRATION LAW  (MOTION FOR FINDINGS ALLOWING CHILD TO PETITION FOR SPECIAL IMMIGRANT JUVENILE STATUS SHOULD HAVE BEEN GRANTED)/SPECIAL IMMIGRANT JUVENILE STATUS (MOTION FOR FINDINGS ALLOWING CHILD TO PETITION FOR SPECIAL IMMIGRANT JUVENILE STATUS SHOULD HAVE BEEN GRANTED)

18% REDUCTION IN INCOME SUFFICIENT TO WARRANT RECALCULATION OF CHILD SUPPORT.

The Fourth Department, reversing Family Court, determined an 18% reduction in father’s income was sufficient to warrant a recalculation of his child support:

… [T]he father cites his significantly reduced income from 2012 to 2013 as the requisite change in circumstances. We agree with the father that such income reduction—approximately 18%—constitutes a sufficient change in circumstances to warrant a recalculation of his child support obligation … . Matter of Brink v Brink, 2017 NY Slip Op 00879, 4th Dept 2-3-17

FAMILY LAW (18% REDUCTION IN INCOME SUFFICIENT TO WARRANT RECALCULATION OF CHILD SUPPORT)/CHILD SUPPORT (18% REDUCTION IN INCOME SUFFICIENT TO WARRANT RECALCULATION OF CHILD SUPPORT)

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