Wills v. Wills
Opinion of the Court
—Order unanimously modified on the law and as modified affirmed without costs in accordance with
The visitation provisions of the order conflict with the court’s decision and thus must be modified to conform to the decision (see, Matter of Edward V., 204 AD2d 1060, 1061). Even as conformed, however, the order improperly delegates the court’s authority to determine issues involving the best interests of the children by conditioning the resumption of unsupervised daytime visitation and the possible later institution of overnight visitation on the recommendations of the psychologist and/or the Law Guardian (see, Matter of Henrietta D. v Jack K., 272 AD2d 995; Matter of Sullivan County Dept, of Social Servs. v Richard C., 260 AD2d 680, 683, Iv dismissed 93 NY2d 958; Shuchter v Shuchter, 259 AD2d 1013). Therefore, we modify the visitation provisions of the order, as conformed to the decision, by vacating those provisions making the resumption of unsupervised daytime visitation, and the possible later institution of overnight visitation, subject to or otherwise contingent on the recommendations of the psychologist and/or the Law Guardian (see, Matter of Henrietta D. v Jack K, supra, at 995).
With respect to defendant’s remaining contentions, which essentially assert that the contempt adjudication is not a valid order of either civil or criminal contempt, we note that plaintiff implicitly concedes that the contempt adjudication may be upheld only as an order of criminal contempt. We agree with defendant that the adjudication of criminal contempt cannot stand, because the court failed to advise defendant of his right to the assistance of counsel or elicit his valid waiver of such right before permitting him to proceed pro se (see, Judiciary Law § 770; Matter of Gaudette v Gaudette, 263 AD2d 620, 621; Matter of Brainard v Brainard, 88 AD2d 996; Matter of Kissel v Kissel, 59 AD2d 1036, 1036-1037; Hickland v Hickland, 56 AD2d 978, 980; see generally, Scott v Illinois, 440 US 367, 373-374; Argersinger v Hamlin, 407 US 25, 37; Annotation, Right to Appointment of Counsel in Contempt Proceedings, 32 ALRSth
Case-law data current through December 31, 2025. Source: CourtListener bulk data.