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
| Court | Appellate Division, Fourth Department |
|---|---|
| Decided | October 9, 2026 |
| Citation | 2026 NY Slip Op 05880 |
| Area of law | Family Law |
| Week | Week ending October 10, 2026 |
| Official text | Official decision: 2026 NY Slip Op 05880 |
| 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 | 1108 |
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.
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