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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
CourtAppellate Division, First Department
DecidedNovember 12, 2026
Citation2026 NY Slip Op 06574
Area of lawFamily Law
WeekWeek ending November 14, 2026
Official textOfficial decision: 2026 NY Slip Op 06574
Publication statusSlip opinions are uncorrected and subject to revision before publication in the Official Reports.
Source feedNew York slip opinion page
Law Watch record id1877

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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Published November 12, 2026. Updated November 12, 2026.