Appellate Division, First Department · November 12, 2026 · 2026 NY Slip Op 06574
Matter of S.L. v R.S.M.
Read the official decision: 2026 NY Slip Op 06574
Holding The Appellate Division affirmed the Family Court’s denial of the father’s petition for custody modification, finding no change in circumstances and upholding the lower court’s credibility determinations. The court also determined that any error in admitting the mother’s diary was harmless because the father failed to demonstrate prejudice.
The court’s words
Family Court properly determined that there was no change in circumstances warranting a modification of the 2018 custody order
2026 NY Slip Op 06574, at the official text
We find no basis to disturb the court's credibility findings, which are afforded great deference on appeal
2026 NY Slip Op 06574, at the official text
the father's brief does not identify the contents of the mother's diary, explain why its admission constituted an improvident exercise of discretion
2026 NY Slip Op 06574, at the official text
| Court | Appellate Division, First Department |
|---|---|
| Decided | November 12, 2026 |
| Citation | 2026 NY Slip Op 06574 |
| Area of law | Family Law |
| Week | Week ending November 14, 2026 |
| Official text | Official decision: 2026 NY Slip Op 06574 |
| 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 | 1877 |
Recommended citation
ESQ HQ, New York Law Watch, Matter of S.L. v R.S.M., 2026 NY Slip Op 06574 (Appellate Division, First Department, November 12, 2026), https://esqhq.com/decisions/2026-ny-slip-op-06574/
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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