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
| Court | Appellate Division, Fourth Department |
|---|---|
| Decided | July 24, 2026 |
| Citation | 2026 NY Slip Op 04709 |
| Area of law | Family Law |
| Week | Week ending July 25, 2026 |
| Official text | Official decision: 2026 NY Slip Op 04709 |
| Publication status | Slip opinions are uncorrected and subject to revision before publication in the Official Reports. |
| Source feed | New York slip opinion page |
| Law Watch record id | 599 |
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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