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COURT SHOULD NOT HAVE GIVEN HUSBAND CREDIT FOR HIGHER CHILD SUPPORT PAYMENTS MADE BEFORE THE LOWER FINAL CHILD SUPPORT AWARD UPON DIVORCE.

The Third Department, in this divorce action, determined that Supreme Court’s attempt to give the husband credit for the difference between the higher child support payments imposed prior to the divorce and the lower payments ordered in the final child support award was error:

… [T]he temporary support payments already made by the husband pursuant to the pendente lite order exceeded the retroactive support obligation set forth by Supreme Court. Absent any statutory authority for recoupment of overpayments of child support and given the “‘strong public policy against restitution or recoupment of [such] overpayments'” … , we conclude that Supreme Court erred in crediting the husband for the temporary child support payments that he made in excess of what he was required to pay under the final child support award … . Sprole v Sprole, 2016 NY Slip Op 08911, 3rd Dept 12-29-16

FAMILY LAW (CHILD SUPPORT, COURT SHOULD NOT HAVE GIVEN HUSBAND CREDIT FOR HIGHER CHILD SUPPORT PAYMENTS MADE BEFORE THE LOWER FINAL CHILD SUPPORT AWARD UPON DIVORCE)/CHILD SUPPORT (CHILD SUPPORT, COURT SHOULD NOT HAVE GIVEN HUSBAND CREDIT FOR HIGHER CHILD SUPPORT PAYMENTS MADE BEFORE THE LOWER FINAL CHILD SUPPORT AWARD UPON DIVORCE)

MOTHER’S PETITION TO MODIFY VISITATION WITH HER DAUGHTER SHOULD HAVE BEEN GRANTED, MOTHER WAS SUCCESSFULLY CONTROLLING HER ADDICTION AND WAS MAINTAINING A FULL TIME JOB.

The Third Department, reversing Family Court, determined mother had sufficiently demonstrated a change in circumstances to warrant unsupervised visitation with her child. Mother was successfully controlling her addiction and was maintaining a full-time job:

“As the party seeking to modify a prior order of visitation, the [mother] bore the initial burden of showing that a change in circumstances has occurred since the entry thereof that is sufficient to warrant Family Court undertaking a best interests analysis in the first instance; assuming that requirement is met, the [mother] then must show that modification of the prior order is necessary in order to ensure the child’s continued best interests” … . In this regard, “expanded visitation is generally favorable absent proof that such visitation is inimical to the child[‘s] welfare” … .

The mother’s modification request stemmed from certain changes that had occurred in both her personal life and the child’s schedule since entry of the prior order. With respect to the child’s schedule, the mother explained that, now that the child was enrolled in school, there was a narrow window of opportunity during the school week (60 to 90 minutes each day) when she could enjoy visitations with her daughter. As to her personal life, the mother testified — without contradiction — that she had completed a detox program, was actively engaged in both group therapy and a community-based support group (Alcoholics Anonymous), the latter of which she attended three or four times each week, had obtained a sponsor (with whom she spoke daily and tried to meet in person twice a month), was participating in a Suboxone treatment program (for which she underwent regular testing to monitor the level of Suboxone in her system), was subject to regular drug testing for illegal substances (all of which came back negative), was successfully maintaining a full-time job and, as of the date of the hearing, had been “clean” for more than one year … . Matter of Beeken v Fredenburg, 2016 NY Slip Op 08919, 3rd Dept 12-29-16

 

FAMILY LAW (MOTHER’S PETITION TO MODIFY VISITATION WITH HER DAUGHTER SHOULD HAVE BEEN GRANTED, MOTHER WAS SUCCESSFULLY CONTROLLING HER ADDICTION AND WAS MAINTAINING A FULL TIME JOB)/VISITATION (FAMILY LAW, MOTHER’S PETITION TO MODIFY VISITATION WITH HER DAUGHTER SHOULD HAVE BEEN GRANTED, MOTHER WAS SUCCESSFULLY CONTROLLING HER ADDICTION AND WAS MAINTAINING A FULL TIME JOB)

FAMILY COURT SHOULD HAVE CONSIDERED PATERNITY BY ESTOPPEL BEFORE ORDERING TEST FOR BIOLOGICAL PATERNITY.

The Fourth Department, reversing Family Court and ordering further proceedings before a different judge, reiterated that a court should consider paternity by estoppel before ordering a test for biological parternity. Here, Gerald, the acknowledged father of the child and the custodial parent of the child, was not a named party in the proceedings (a paternity petition brought by the mother naming another party, Shane, as the father). Shane appeared and stated he wanted nothing to do with child. Yet the court ordered a paternity test without making Gerald a party and without notifying him:

“Family Court should consider paternity by estoppel before it decides whether to test for biological paternity” … . That did not occur here because Gerald was not a named party in the paternity proceeding and did not otherwise appear when the court ordered Shane to submit to a genetic marker test, so he did not have the opportunity to raise the doctrine of estoppel. The court should have joined Gerald in that proceeding or otherwise notified him before it ordered the test … . After all, Gerald was not only the acknowledged father of the child, but was the custodial parent of the child, and the court was well aware of those facts inasmuch as it had issued the custody orders. The court made it clear in its decision, however, that even if Gerald had made a timely objection and raised the defense earlier, the court nevertheless would have ordered the test because the child was young and “the truth is important.” That is contrary to both the plain language of the statute and statements of law by the Court of Appeals. Matter of Jennifer L. v Gerald S., 2016 NY Slip Op 08730, 4th Dept 12-23-16

FAMILY LAW (FAMILY COURT SHOULD HAVE CONSIDERED PATERNITY BY ESTOPPEL BEFORE ORDERING TEST FOR BIOLOGICAL PATERNITY)/PATERNITY (FAMILY COURT SHOULD HAVE CONSIDERED PATERNITY BY ESTOPPEL BEFORE ORDERING TEST FOR BIOLOGICAL PATERNITY)

COURT ERRED IN CLASSIFYING HOUSE PURCHASED BEFORE MARRIAGE AS MARITAL PROPERTY, HOWEVER THE APPRECIATION IN THE VALUE OF THE HOUSE WAS MARITAL PROPERTY.

The Fourth Department determined a house purchased by the husband prior to marriage was his separate property, despite the fact it was used a the marital residence and proceeds from the sale were used to purchase a marital residence. The appreciation in the value of the house, however, was marital property:

It was undisputed that the Seneca Hill Property was purchased by defendant prior to the marriage, and we conclude that it was not transmuted into marital property when the parties used it as the marital residence for approximately two years, or by virtue of defendant having used some of the sale proceeds therefrom to assist in funding the purchase of a new marital residence … . Defendant was therefore entitled to a credit for his separate property contributions to the marital estate … . We further conclude, however, that the appreciated value of the Seneca Hill Property that the court determined to be attributable to the contributions of plaintiff should have been classified as marital property … . Hart v Hart, 2016 NY Slip Op 08692, 4th Dept 12-23-16

FAMILY LAW (MARITAL PROPERTY, COURT ERRED IN CLASSIFYING HOUSE PURCHASED BEFORE MARRIAGE AS MARITAL PROPERTY, HOWEVER THE APPRECIATION IN THE VALUE OF THE HOUSE WAS MARITAL PROPERTY)/EQUITABLE DISTRIBUTION (MARITAL PROPERTY, COURT ERRED IN CLASSIFYING HOUSE PURCHASED BEFORE MARRIAGE AS MARITAL PROPERTY, HOWEVER THE APPRECIATION IN THE VALUE OF THE HOUSE WAS MARITAL PROPERTY)/MARITAL PROPERTY (COURT ERRED IN CLASSIFYING HOUSE PURCHASED BEFORE MARRIAGE AS MARITAL PROPERTY, HOWEVER THE APPRECIATION IN THE VALUE OF THE HOUSE WAS MARITAL PROPERTY)/SEPARATE PROPERTY (EQUITABLE DISTRIBUTION, COURT ERRED IN CLASSIFYING HOUSE PURCHASED BEFORE MARRIAGE AS MARITAL PROPERTY, HOWEVER THE APPRECIATION IN THE VALUE OF THE HOUSE WAS MARITAL PROPERTY)/APPRECIATION IN VALUE (EQUITABLE DISTRIBUTION, COURT ERRED IN CLASSIFYING HOUSE PURCHASED BEFORE MARRIAGE AS MARITAL PROPERTY, HOWEVER THE APPRECIATION IN THE VALUE OF THE HOUSE WAS MARITAL PROPERTY)

CEREMONIAL MARRIAGE SUFFICIENTLY PROVEN, CHILD ENTITLED TO SUPPORT.

The First Department, in a full-fledged opinion by Justice Acosta, affirmed the support magistrate’s finding that a ceremonial marriage had taken place and, therefore, the child of the marriage was entitled to support from the father. The mother described the Islamic marriage ceremony, and presented some additional proof (photos and a daughter’s testimony). Father acknowledged living with mother and relying on her to raise his children, but denied the marriage:

The presumption of legitimacy has since been codified in the Family Court Act, which provides, “A child born of parents who at any time prior or subsequent to the birth of said child shall have entered into a ceremonial marriage shall be deemed the legitimate child of both parents for all purposes of [support proceedings] regardless of the validity of such marriage” … . A ceremonial marriage need not take any particular form, provided that the parties solemnly declare in the presence of a clergyman or magistrate, and at least one witness, that they intend to be married … .

… New York courts … treat the presumption as a rebuttable one … . To rebut the presumption, the challenger must disprove legitimacy by clear and convincing evidence … . The court’s determination after a hearing that respondent and [mother] entered into a ceremonial marriage is supported by the evidence and the court’s credibility determinations, which “are entitled to great weight, since the nisi prius court is in a better position to evaluate the witnesses” … . Therefore, we affirm the court’s factual determination that a ceremonial marriage took place. Matter of Commissioner of Social Servs. v B.C., 2016 NY Slip Op 08613, 1st Dept 12-22-16

 

FAMILY LAW (CEREMONIAL MARRIAGE SUFFICIENTLY PROVEN, CHILD ENTITLED TO SUPPORT)/SUPPORT (FAMILY LAW, CEREMONIAL MARRIAGE SUFFICIENTLY PROVEN, CHILD ENTITLED TO SUPPORT)/CEREMONIAL MARRIAGE (FAMILY LAW, CHILD SUPPORT, CEREMONIAL MARRIAGE SUFFICIENTLY PROVEN, CHILD ENTITLED TO SUPPORT)/CHILD SUPPORT (CEREMONIAL MARRIAGE SUFFICIENTLY PROVEN, CHILD ENTITLED TO SUPPORT)/LEGITIMACY, PRESUMPTION OF (CEREMONIAL MARRIAGE SUFFICIENTLY PROVEN, CHILD ENTITLED TO SUPPORT)

SURROGATE’S COURT DOES NOT HAVE THE AUTHORITY TO ABROGATE OR VACATE A FOREIGN ORDER OF ADOPTION.

The Second Department determined Surrogate’s Court did not have the authority under the Domestic Relations Law to deny recognition of, or vacate, adoption orders issued to petitioners by a Russian court. After adopting the children, petitioners learned the children had serious mental health problems which required placement in a residential psychiatric treatment facility. Petitioners then sought relief from the Russian adoption orders:

… [T]he Surrogate’s Court lacked authority under Domestic Relations Law § 111-c to deny recognition of the adoption order. Although a court may deny a petition for registration of a foreign adoption order on the ground that it does not satisfy the requirements set forth in Domestic Relations Law § 111-c(1) … , the statute, by its plain language, was not intended to function as a means to abrogate a foreign adoption or deny recognition of a foreign adoption order on the basis of fraud. …

The Surrogate’s Court similarly lacked authority under Domestic Relations Law § 114(3) to vacate the adoption order. That statute provides that, “[i]n like manner as a court of general jurisdiction exercises such powers, a judge or surrogate of a court in which the order of adoption was made may open, vacate or set aside such order of adoption for fraud, newly discovered evidence or other sufficient cause.” … The plain language of that statute only empowers a New York court to vacate its own adoption orders, and not those issued in a foreign sovereign nation … . Matter of Child A (Parent M.), 2016 NY Slip Op 08510, 2nd Dept 12-21-16

 

FAMILY LAW (SURROGATE’S COURT DOES NOT HAVE THE AUTHORITY TO ABROGATE OR VACATE A FOREIGN ORDER OF ADOPTION)/SURROGATE’S COURT (FAMILY LAW, ADOPTION, SURROGATE’S COURT DOES NOT HAVE THE AUTHORITY TO ABROGATE OR VACATE A FOREIGN ORDER OF ADOPTION)/ADOPTION (SURROGATE’S COURT DOES NOT HAVE THE AUTHORITY TO ABROGATE OR VACATE A FOREIGN ORDER OF ADOPTION)/DOMESTIC RELATIONS LAW (SURROGATE’S COURT DOES NOT HAVE THE AUTHORITY TO ABROGATE OR VACATE A FOREIGN ORDER OF ADOPTION)

CONSTRUCTIVE TRUST PROPERLY IMPOSED UPON PROPERTY PURCHASED AND IMPROVED WITH MARITAL FUNDS BUT TITLED TO ANOTHER.

The Second Department determined a constructive trust was properly imposed on Florida property in this divorce action. The wife, who sought the constructive trust, alleged that marital funds were used to buy and improve the property and the property was placed in her husband’s father’s (Boris’s) name for tax purposes:

” The elements of a constructive trust are (1) a fiduciary or confidential relationship; (2) an express or implied promise; (3) a transfer in reliance on the promise; and (4) unjust enrichment'” … . “[A]s these elements serve only as a guideline, a constructive trust may still be imposed even if all of the elements are not established” … . “Thus, although the elements of a constructive trust must be proved by clear and convincing evidence … , [t]he constructive trust doctrine is given broad scope to respond to all human implications of a transaction in order to give expression to the conscience of equity and to satisfy the demands of justice'” … .

Here, evidence adduced at the hearing showed that the wife was related to the husband and Boris through marriage and that Boris allowed the Florida apartment to be used solely by the husband and wife as their vacation home for many years. Therefore, the first element for the imposition of a constructive trust was satisfied … . The wife also satisfied the second element by demonstrating the existence of an implied promise that [husband’s father] was holding title to the Florida apartment for purposes convenient to the husband and that the apartment belonged to the husband and wife … . She also demonstrated that, in reliance on that implied promise, marital funds were used to purchase the apartment and to make renovations costing more than $150,000 … . Furthermore, the wife demonstrated that a constructive trust was necessary ” to satisfy the demands of justice'” … . Kaprov v Stalinsky, 2016 NY Slip Op 08509, 2nd Dept 12-21-16

 

FAMILY LAW (EQUITABLE DISTRIBUTION, CONSTRUCTIVE TRUST PROPERLY IMPOSED UPON PROPERTY PURCHASED AND IMPROVED WITH MARITAL FUNDS BUT TITLED TO ANOTHER)/EQUITABLE DISTRIBUTION (CONSTRUCTIVE TRUST PROPERLY IMPOSED UPON PROPERTY PURCHASED AND IMPROVED WITH MARITAL FUNDS BUT TITLED TO ANOTHER)/CONSTRUCTIVE TRUST (EQUITABLE DISTRIBUTION, CONSTRUCTIVE TRUST PROPERLY IMPOSED UPON PROPERTY PURCHASED AND IMPROVED WITH MARITAL FUNDS BUT TITLED TO ANOTHER)

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TESTIMONY AT THE FACT FINDING HEARING ABOUT THE IDENTIFICATION PROCEDURE SHOULD NOT HAVE BEEN ADMITTED BECAUSE IT DIFFERED SIGNIFICANTLY FROM THE PROCEDURE DESCRIBED IN THE VOLUNTARY DISCLOSURE FORM.

The First Department, reversing Family Court’s juvenile delinquent adjudication, determined the testimony at the fact finding hearing about the identification procedure was so different from the description in the voluntary disclosure form [VDF] that the identification evidence should not have been admitted:

In a voluntary disclosure form [VDF], the presentment agency informed appellant that the complainant identified him inside a restaurant. Consistent with this notice, the arresting detective testified at the suppression hearing that he saw appellant and two companions, whom he had been following, enter the restaurant, that the complainant arrived at the scene, and that despite the officer’s instruction for the complainant to wait outside, the complainant entered the restaurant shortly after the detective did and there identified appellant. Based on this testimony, the court denied suppression, finding that the identification was a “spontaneous or un-arranged identification.” However, when the complainant ultimately testified at the fact-finding hearing, he testified that he never entered the restaurant, but rather that he identified appellant after the detective brought the three boys out of the restaurant and lined them up against a wall.

Although an inconsequential defect in a notice may be excused … , here the discrepancy between the two accounts of the identification was not inconsequential, but rather reflected that the VDF provided inadequate notice of the evidence the presentment agency intended to present at the fact-finding hearing … . Accordingly, the court should have granted appellant’s Family Ct Act § 330.2(2) motion to preclude identification evidence, which was made after the complainant testified regarding the identification procedure outside the restaurant. Matter of Deavan W., 2016 NY Slip Op 08469, 1st Dept 12-15-16

 

FAMILY LAW (TESTIMONY AT THE FACT FINDING HEARING ABOUT THE IDENTIFICATION PROCEDURE SHOULD NOT HAVE BEEN ADMITTED BECAUSE IT DIFFERED SIGNIFICANTLY FROM THE PROCEDURE DESCRIBED IN THE VOLUNTARY DISCLOSURE FORM)/CRIMINAL LAW (FAMILY COURT, JUVENILE DELINQUENCY, TESTIMONY AT THE FACT FINDING HEARING ABOUT THE IDENTIFICATION PROCEDURE SHOULD NOT HAVE BEEN ADMITTED BECAUSE IT DIFFERED SIGNIFICANTLY FROM THE PROCEDURE DESCRIBED IN THE VOLUNTARY DISCLOSURE FORM)/JUVENILE DELINQUENCY (TESTIMONY AT THE FACT FINDING HEARING ABOUT THE IDENTIFICATION PROCEDURE SHOULD NOT HAVE BEEN ADMITTED BECAUSE IT DIFFERED SIGNIFICANTLY FROM THE PROCEDURE DESCRIBED IN THE VOLUNTARY DISCLOSURE FORM)/EVIDENCE (FAMILY COURT, JUVENILE DELINQUENCY, TESTIMONY AT THE FACT FINDING HEARING ABOUT THE IDENTIFICATION PROCEDURE SHOULD NOT HAVE BEEN ADMITTED BECAUSE IT DIFFERED SIGNIFICANTLY FROM THE PROCEDURE DESCRIBED IN THE VOLUNTARY DISCLOSURE FORM)/IDENTIFICATION (FAMILY COURT, JUVENILE DELINQUENCY, TESTIMONY AT THE FACT FINDING HEARING ABOUT THE IDENTIFICATION PROCEDURE SHOULD NOT HAVE BEEN ADMITTED BECAUSE IT DIFFERED SIGNIFICANTLY FROM THE PROCEDURE DESCRIBED IN THE VOLUNTARY DISCLOSURE FORM)

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PROPER FOUNDATION HAD BEEN LAID, FACEBOOK MESSAGES BETWEEN MOTHER AND CHILD SHOULD HAVE BEEN ALLOWED IN EVIDENCE IN THIS ABANDONMENT PROCEEDING.

In an abandonment proceeding, Family Court erred when it would not allow Facebook messages between mother and child into evidence. The Third Department determined a proper foundation for the Facebook messages had been laid. The messages were crucial to mother’s attempt to demonstrate she had maintained contact with her child:

A recorded conversation — such as a printed copy of the content of a set of cell phone instant messages — may be authenticated through, among other methods, the “testimony of a participant in the conversation that it is a complete andaccurate reproduction of the conversation and has not been altered” … . Notably, “[t]he credibility of the authenticating witness and any motive she [or he] may have had to alter the evidence go to the weight to be accorded this evidence, rather than its admissibility” … . Respondent testified that she was present when her counsel printed the Facebook messages at his office, and that she reviewed the entire document to ensure that it was a full and complete copy. The … stipulation and respondent’s testimony, when combined with her adult son’s testimony confirming that he had provided respondent with his account information, password and permission to use the account for communication with the child, constituted a sufficient foundation for the admission into evidence of the printed messages and her related testimony … .

By erroneously precluding this proffered evidence, Family Court deprived respondent of her due process right to a full and fair opportunity to be heard. In a proceeding to terminate parental rights “the court is obliged to ensure that the proceeding is fair and that due process is afforded to an individual whose parental rights may be terminated” … . The frequency and content of these Facebook communications are relevant in determining whether respondent initiated or maintained substantial contact with the child during the statutory period … .  Matter of Colby II. (Sheba II.), 2016 NY Slip Op 08402, 3rd Dept 12-15-16

 

FAMILY LAW (PROPER FOUNDATION HAD BEEN LAID, FACEBOOK MESSAGES BETWEEN MOTHER AND CHILD SHOULD HAVE BEEN ALLOWED IN EVIDENCE IN THIS ABANDONMENT PROCEEDING)/ABANDONMENT (FAMILY LAW, PROPER FOUNDATION HAD BEEN LAID, FACEBOOK MESSAGES BETWEEN MOTHER AND CHILD SHOULD HAVE BEEN ALLOWED IN EVIDENCE IN THIS ABANDONMENT PROCEEDING)/EVIDENCE (FAMILY LAW, PROPER FOUNDATION HAD BEEN LAID, FACEBOOK MESSAGES BETWEEN MOTHER AND CHILD SHOULD HAVE BEEN ALLOWED IN EVIDENCE IN THIS ABANDONMENT PROCEEDING)/FACEBOOK MESSAGES (FAMILY LAW, PROPER FOUNDATION HAD BEEN LAID, FACEBOOK MESSAGES BETWEEN MOTHER AND CHILD SHOULD HAVE BEEN ALLOWED IN EVIDENCE IN THIS ABANDONMENT PROCEEDING)/RECORDED CONVERSATION (FACEBOOK MESSAGES, FAMILY LAW, PROPER FOUNDATION HAD BEEN LAID, FACEBOOK MESSAGES BETWEEN MOTHER AND CHILD SHOULD HAVE BEEN ALLOWED IN EVIDENCE IN THIS ABANDONMENT PROCEEDING)

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HEARING SHOULD HAVE BEEN HELD ON BIRTH PARENT’S PETITION TO ENFORCE A POSTADOPTION AGREEMENT ALLOWING THE BIRTH PARENT’S VISITATION WITH THE CHILD.

The Third Department determined a hearing should have been held on a birth parent’s petition to enforce a postadoption agreement which allowed visitation by the parent:

Family Court erred in dismissing the petition without an evidentiary hearing. Pursuant to Domestic Relations Law § 112-b (4), birth parents and adoptive parents may enter into a legally enforceable agreement regarding postadoption contact that may thereafter be enforced by filing a petition in Family Court … . Enforcement of a postadoption contact agreement, however, “will only be ordered if it is determined to be in the child’s best interests” … , and “[a]n evidentiary hearing is generally necessary to determine what is in the best interests of the child” … .

Here, while there were three appearances in Family Court on the petition at which the interested parties made factual representations, primarily through counsel, and legal arguments on the merits of the petition, no testimony was taken and no documentary evidence was admitted for consideration. The child’s adoptive parents and the attorney for the child opposed enforcement of the postadoption contact agreement and any contact between the child and petitioner based upon, among other factors, an alleged multi-year lapse in contact between petitioner and the child. The information submitted to the court raised factual questions regarding whether visits with petitioner would be in the child’s best interests or detrimental to those interests, necessitating an evidentiary hearing on that determinative issue … .

Further, the adoptive parents are persons whose interests may be adversely or inequitably affected by an order enforcing the postadoption contact agreement and, therefore, they should have been named as parties … . Matter of Lynn X. (Joseph W.), 2016 NY Slip Op 08415, 3rd Dept 12-15-16

 

FAMILY LAW (HEARING SHOULD HAVE BEEN HELD ON BIRTH PARENT’S PETITION TO ENFORCE A POSTADOPTION AGREEMENT ALLOWING THE BIRTH PARENT’S VISITATION WITH THE CHILD)/POSTADOPTION AGREEMENT (HEARING SHOULD HAVE BEEN HELD ON BIRTH PARENT’S PETITION TO ENFORCE A POSTADOPTION AGREEMENT ALLOWING THE BIRTH PARENT’S VISITATION WITH THE CHILD)/VISITATION (FAMILY LAW, HEARING SHOULD HAVE BEEN HELD ON BIRTH PARENT’S PETITION TO ENFORCE A POSTADOPTION AGREEMENT ALLOWING THE BIRTH PARENT’S VISITATION WITH THE CHILD)/ADOPTION (POSTADOPTION AGREEMENTS, HEARING SHOULD HAVE BEEN HELD ON BIRTH PARENT’S PETITION TO ENFORCE A POSTADOPTION AGREEMENT ALLOWING THE BIRTH PARENT’S VISITATION WITH THE CHILD)

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