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Appellate Division, Fourth Department · October 9, 2026 · 2026 NY Slip Op 05876

Matter of Buchholz v Trombley

Read the official decision: 2026 NY Slip Op 05876

Holding The Appellate Division affirmed the Family Court’s denial of the mother’s petition to modify custody and visitation, finding that the lower court’s best interests determination was supported by a sound and substantial basis in the record. The court also held that the mother’s claim of judicial bias was unpreserved because she failed to move for recusal.

The court’s words

the court must consider all factors that could impact the best interests of the child, including the existing custody arrangement

2026 NY Slip Op 05876, at the official text

a court's determination regarding custody [and visitation issues], based upon a first-hand assessment of the credibility of the witnesses

2026 NY Slip Op 05876, at the official text

the mother's contention that the court was biased against her is unpreserved for our review inasmuch as she failed to make a motion

2026 NY Slip Op 05876, at the official text
CourtAppellate Division, Fourth Department
DecidedOctober 9, 2026
Citation2026 NY Slip Op 05876
Area of lawFamily Law
WeekWeek ending October 10, 2026
Official textOfficial decision: 2026 NY Slip Op 05876
Publication statusSlip opinions are uncorrected and subject to revision before publication in the Official Reports.
Source feedNew York slip opinion page
Law Watch record id1104

Recommended citation

ESQ HQ, New York Law Watch, Matter of Buchholz v Trombley, 2026 NY Slip Op 05876 (Appellate Division, Fourth Department, October 9, 2026), https://esqhq.com/decisions/2026-ny-slip-op-05876/

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 October 9, 2026. Updated October 9, 2026.