Appellate Division, First Department · October 6, 2026 · 2026 NY Slip Op 05713
Matter of Partia A. v Thierno D.
Read the official decision: 2026 NY Slip Op 05713
Holding The father’s decision to proceed pro se constituted a valid waiver of his right to counsel because he repeatedly chose to retain private counsel without requesting assigned counsel or demonstrating financial inability. The court properly denied further adjournments and affirmed the custody order, finding the waiver was knowing, intelligent, and voluntary.
The court’s words
the father's repeated election to pursue privately retained counsel, without any indication that he was financially unable to do so
2026 NY Slip Op 05713, at the official text
the record need only demonstrate that the litigant was aware of the dangers and disadvantages of proceeding without counsel
2026 NY Slip Op 05713, at the official text
| Court | Appellate Division, First Department |
|---|---|
| Decided | October 6, 2026 |
| Citation | 2026 NY Slip Op 05713 |
| Area of law | Family Law |
| Week | Week ending October 10, 2026 |
| Official text | Official decision: 2026 NY Slip Op 05713 |
| 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 | 935 |
Recommended citation
ESQ HQ, New York Law Watch, Matter of Partia A. v Thierno D., 2026 NY Slip Op 05713 (Appellate Division, First Department, October 6, 2026), https://esqhq.com/decisions/2026-ny-slip-op-05713/
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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