Appellate Division, Third Department · October 22, 2026 · 2026 NY Slip Op 06182
Four-Rosenbaum v Four-Rosenbaum
Read the official decision: 2026 NY Slip Op 06182
Holding The Supreme Court erred by analyzing the motion to limit child support arrears under Family Ct Act § 451 rather than Family Ct Act § 413 (1) (g), which prevents arrears from accruing if income is below the federal poverty guidelines. The matter was remitted for a hearing to determine if the statutory requirements for preventing arrears accrual were met.
The court’s words
unpaid child support arrears in excess of [$500] shall not accrue
2026 NY Slip Op 06182, at the official text
the relevant inquiry before Supreme Court was not whether the wife established good cause
2026 NY Slip Op 06182, at the official text
the record is insufficient to determine whether Family Ct Act § 413 (1) (g) precluded the accrual
2026 NY Slip Op 06182, at the official text
| Court | Appellate Division, Third Department |
|---|---|
| Decided | October 22, 2026 |
| Citation | 2026 NY Slip Op 06182 |
| Area of law | Family Law |
| Week | Week ending October 24, 2026 |
| Official text | Official decision: 2026 NY Slip Op 06182 |
| 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 | 1464 |
Recommended citation
ESQ HQ, New York Law Watch, Four-Rosenbaum v Four-Rosenbaum, 2026 NY Slip Op 06182 (Appellate Division, Third Department, October 22, 2026), https://esqhq.com/decisions/2026-ny-slip-op-06182/
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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