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Appellate Division, Fourth Department · July 24, 2026 · 2026 NY Slip Op 04709

Erik T.K. v Anthony W.C.

Read the official decision: 2026 NY Slip Op 04709

Holding The Family Court properly determined that the biological father failed to establish a substantial relationship with the child, thereby failing to establish his right of consent to the adoption. Consequently, the court did not need to proceed to the second step of determining whether the father forfeited that right through abandonment.

The court’s words

the court must first decide whether the [biological] father has demonstrated a substantial relationship with his child conferring the right of consent

2026 NY Slip Op 04709, at the official text

the record supports the court's determination that respondent failed to establish sufficient visitation with the child or communication with the child or the child's mother

2026 NY Slip Op 04709, at the official text

the record, viewed in totality, reveals that [he] received meaningful representation

2026 NY Slip Op 04709, at the official text
CourtAppellate Division, Fourth Department
DecidedJuly 24, 2026
Citation2026 NY Slip Op 04709
Area of lawFamily Law
WeekWeek ending July 25, 2026
Official textOfficial decision: 2026 NY Slip Op 04709
Publication statusSlip opinions are uncorrected and subject to revision before publication in the Official Reports.
Source feedNew York slip opinion page
Law Watch record id599

Recommended citation

ESQ HQ, New York Law Watch, Erik T.K. v Anthony W.C., 2026 NY Slip Op 04709 (Appellate Division, Fourth Department, July 24, 2026), https://esqhq.com/decisions/2026-ny-slip-op-04709/

How this record was made

Holding drafted by Law Watch’s in-house model, graded by three reviewers; every quotation verified word for word against the official text.

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Published July 24, 2026. Updated July 24, 2026.