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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
CourtAppellate Division, Third Department
DecidedOctober 22, 2026
Citation2026 NY Slip Op 06182
Area of lawFamily Law
WeekWeek ending October 24, 2026
Official textOfficial decision: 2026 NY Slip Op 06182
Publication statusSlip opinions are uncorrected and subject to revision before publication in the Official Reports.
Source feedNew York slip opinion page
Law Watch record id1464

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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Published October 22, 2026. Updated October 22, 2026.