ESQ HQNEW YORK LAW WATCH

Appellate Division, Fourth Department · October 9, 2026 · 2026 NY Slip Op 05880

Matter of Hayes v Porter

Read the official decision: 2026 NY Slip Op 05880

Holding The court affirmed the Family Court’s order denying the father parenting time, finding that the decision was supported by a sound and substantial basis in the record regarding the strained relationship and the father’s lack of accountability. The court further held that ordering the father’s substantial compliance with intensive counseling as a condition for future modification petitions was not an improper prerequisite to visitation.

The court’s words

Family Court's determination that the father shall not have parenting time with the child has a sound and substantial basis in the record

2026 NY Slip Op 05880, at the official text

the father and the child had a strained relationship and that the father taunted and teased the child

2026 NY Slip Op 05880, at the official text

the father lacked of emotional self-regulation when angry, which was distressing to the child and contributed to his reluctance to visit the father

2026 NY Slip Op 05880, at the official text

the court did not err in ordering that the father's substantial compliance, engagement and progress with intensive individual counseling

2026 NY Slip Op 05880, at the official text
CourtAppellate Division, Fourth Department
DecidedOctober 9, 2026
Citation2026 NY Slip Op 05880
Area of lawFamily Law
WeekWeek ending October 10, 2026
Official textOfficial decision: 2026 NY Slip Op 05880
Publication statusSlip opinions are uncorrected and subject to revision before publication in the Official Reports.
Source feedNew York slip opinion page
Law Watch record id1108

Recommended citation

ESQ HQ, New York Law Watch, Matter of Hayes v Porter, 2026 NY Slip Op 05880 (Appellate Division, Fourth Department, October 9, 2026), https://esqhq.com/decisions/2026-ny-slip-op-05880/

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.

Read how Law Watch works

Published October 9, 2026. Updated October 9, 2026.