Smith v. Brown
Opinion of the Court
—Order unanimously reversed on the law without costs and matter remitted to Erie County Family Court for further proceedings in accordance with the following Memorandum: “An award of custody, whether temporary or permanent, must be based on the best interests of the child” (Matter of Farrelly-Brew v Moore, 221 AD2d 1000). It is well established that determinations affecting custody should be made following a full evidentiary hearing, not on the basis of conflicting allegations (see, Matter of Naughton-General v Naughton, 242 AD2d 937, 938; Van Etten v Van Etten, 207 AD2d 992; see also, Matter of Smith v Patrowski, 226 AD2d 1073). Family Court was justifiably concerned about the injuries that the child suffered while in the care of respondent as well as the subsequent failure of re
In addition, we note that the record is silent with respect to whether counsel gave their clients advance notice of their motions to withdraw on the day scheduled for trial. Although this issue is not raised on appeal, we express our concern that parents’ rights to representation be protected (see, Matter of Meko M., 272 AD2d 953 [decided herewith]). (Appeal from Order of Erie County Family Court, Dillon, J. — Custody.) Present— Pigott, Jr., P. J., Pine, Scudder and Kehoe, JJ.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.