ESQ HQNEW YORK LAW WATCH

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
CourtAppellate Division, First Department
DecidedOctober 20, 2026
Citation2026 NY Slip Op 06067
Area of lawFamily Law
WeekWeek ending October 24, 2026
Official textOfficial decision: 2026 NY Slip Op 06067
Publication statusSlip opinions are uncorrected and subject to revision before publication in the Official Reports.
Source feedNew York slip opinion page
Law Watch record id1327

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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Published October 20, 2026. Updated October 20, 2026.