Appellate Division, First Department · October 20, 2026 · 2026 NY Slip Op 06067
Matter of S.B.N. (J.N.)
Read the official decision: 2026 NY Slip Op 06067
Holding The court affirmed the termination of the mother’s parental rights, finding that clear and convincing evidence established her inability to provide proper care due to mental illness. The expert’s opinion was deemed competent despite the lack of direct observation of the mother’s interactions with the children.
The court’s words
Petitioner established by clear and convincing evidence that, due to the mother's mental illness, the mother is presently and for the foreseeable future unable to provide proper and adequate care for the subject children
2026 NY Slip Op 06067, at the official text
The expert opined that the mother suffers from schizoaffective disorder, bipolar type, which manifests in delusions and aggressive behavior
2026 NY Slip Op 06067, at the official text
The expert was not required to observe the mother's interactions with the children to provide a competent foundation for her professional opinion
2026 NY Slip Op 06067, at the official text
| Court | Appellate Division, First Department |
|---|---|
| Decided | October 20, 2026 |
| Citation | 2026 NY Slip Op 06067 |
| Area of law | Family Law |
| Week | Week ending October 24, 2026 |
| Official text | Official decision: 2026 NY Slip Op 06067 |
| 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 | 1327 |
Recommended citation
ESQ HQ, New York Law Watch, Matter of S.B.N. (J.N.), 2026 NY Slip Op 06067 (Appellate Division, First Department, October 20, 2026), https://esqhq.com/decisions/2026-ny-slip-op-06067/
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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