Posts Tagged Grounds

Intro to Evidence: “I’ve Got Proof!!!” (or In Support of the Humble Document)

Fairly often, I deal with people going through a divorce who tell me “…and I have proof that he/she is cheating on me, I have a [text/voice-mail/email/telephone recording]!”   Lets face it, most people reading this probably are not lawyers and probably don’t know that the rules of evidence exist, much less what they are.  So I’m going to give a short primer on “proof” and what it means to you.

First, proof is not of much use unless you are going to have a trial.  Sure, you can threaten that you have it, and try to use it as leverage in bargaining for a settlement, but no judge will ever consider it for anything if you are not going to have a trial.  So unless you’re in trial mode (for some god-awful reason) the Judge is NOT going to consider your proof.

Second, proof is completely worthless if it is not in an admissible form.  This means the proof cannot be hear-say (hearsay is an out of court statement offered to prove the truth of the matter asserted, try and wrap your brain around that), or it must fall within one of the exceptions to the hear-say rule (there are simply too many to list here, you’ll need to go check a textbook for all the exceptions), it must be properly introduced to the Court (this is called laying a foundation, check the same textbook you looked at for exceptions to the hear-say rule, there’s probably a chapter or two devoted to introduction of evidence), it must then be offered into evidence and will be subject to voire dire by the opposing attorney (yup, check the text book for that too).  Once you jump through all these hurdles, your proof may, or may not be entered into evidence.   But you’re not finished…

Your proof will not mean too much if it is not relevant.  Your proof (whatever it may consist of) can be as iron-clad as the Tommy Lee-Pam Anderson sex tape… but if it is not relevant to your case, it is useless and will not be admitted to evidence.  So what does that mean?  It means that if you have a video of your soon-to-be-ex-husband bopping his secretary on your kitchen table while holding a copy of the New York Times up to the camera (to prove the date), and he is the one suing you for divorce and you agree that you want to be divorced and grounds are not at issue in the proceedings, the video is irrelevant and gets you nothing.

But, you say, “Chuck… that’s absurd!  I’ve got the old man bopping his secretary on MY kitchen table, and you tell me it’s worthless???  How can this be???”  I say to you, CORRECT!  The video would certainly be relevant to proving grounds of adultery, but if grounds are not at issue, the tape is irrelevant, and thus would not likely be admitted into evidence at trial.

Remember, in New York State, a divorce consists of the divorce itself PLUS dealing with the ancillary issues of child custody and visitation, equitable distribution, child support, and spousal maintenance.  The video would certainly show that soon-to-be-ex-hubby has poor taste, and probably that he’s a big jerk.  But it has little to no bearing on any of the ancillary issues (unless he was bopping away with the kids there to see it, or some other unlikely series of events unfolded around the incident).  In New York, you don’t get a bigger piece of the marital pie in equitable distribution because you were cheated on.  You might get a bigger chunk if there was wasteful dissipation or conduct so egregious that it “shocks the conscience” (as the Court of Appeals might say), but the hypothetical scenario here would not meet that criteria (yes, I know that saddens many of you).

Another thing to think about with your “proof” is how do you prove what it actually is?  So you have a picture of the dented bed-frame that your wife smashed with a baseball bat when she was trying to smash your head in, in a drunken rage?  That’s GREAT!  but the best evidence rule says you should have brought in the whole damned bed-frame.  Forget that for a second and lets talk about the picture.  The smashing happened in 1995, and you took the picture last week.  Bad news, you can only go back 5 years in a divorce.  More bad news, your wife is probably going to say “Oh no, that dent was from the time we moved into the new apartment and he dropped it going up the stairs.”   So what do you really have in that picture?  Have you got proof that your wife went nuts and tried to kill you with a baseball bat?  Nope.  But you have some excellent evidence that you have a dented bed-frame.

Lets talk about wire-tapping crimes for a minute!!!  It seems like everyone wants to tape their spouse these days.  Maybe it’s because of the easy access to electronics, maybe it’s because the moon is full, I just don’t know.  In New York, you can tape a telephone conversation so long as one of the parties to the conversation is aware that it is being taped.  I still don’t usually recommend it, for a host of reasons.  These taped conversations always sound contrived; they rarely wind up being the smoking gun that one thinks they are; and a judge NEVER wants to be bothered to listen to them at trial.  Nevertheless, I’m positive some of you will go to the Spy Outlet and put the tape recorder on your phone anyway.  So please realize, that you are going to be committing all kinds of crimes if you leave the tape recorder on the line when you are not on it, or you secretly record a conversation between your spouse and her paramour that you are not a party to.  In the end, the best advice, is don’t do the tape recording thing… it’s usually not worth the time, unless your attorney specifically tells you to do it.

Text messages– a personal favorite of mine.  So you have text messages of your husband saying he is hiding millions of dollars in a Swiss bank account and you’ll never get it.  Those will be tough to get into evidence.  First, how do you put the text message into evidence?  Sure you can get the phone records, but they only keep text messages on the servers for about 48 hours, then they are deleted.  Are you going to give the judge your phone and say “here they are, I’d like to admit my phone into evidence”???  Kiss your phone goodbye.  And besides, the judge is not going to take your phone into evidence and try to retrieve text messages from it, judges have better things to do.  Next, how do you prove who sent the text message?  Your husband is going to say he lent the phone to his buddy who sent the text as a joke.  You weren’t there to see him press the buttons, so how exactly can you prove it was your husband who sent the text?  The answer is, you probably can’t, and your proof won’t come into evidence.

Emails– see text messages.  But emails are even better, now the guilty husband also gets to say that a hacker stole his password and he hasn’t had access to that email address in two months.  Try and disprove that one in a courtroom with a judge who is late for a tee time.

All things being equal, I think that the vast majority of judges don’t really want to have to consider your proof by [voice-mail/text/email/video].  They would rather hear the testimony of the parties and see your bank records that were properly subpoenaed and submitted and prove that there is $705.49 in your checking account.  Documents are tangible, they are neat, they are something judges are familiar with, and they don’t require legal acrobatics to get them into evidence.  Judges, it seems by nature, don’t want to break new ground and be the first in the county to let text messages into evidence at trial.  They seem to dislike the necessity of setting up a TV in the Courtroom, unless it’s going to be an incredibly exciting and relevant show!  So, I advocate for the humble document.  When it comes to proof, a written document, that can be authenticated (ex. a letter signed by your husband, with the date on it, to his bank saying transfer all my assets to that Swiss account) remains the gold standard in evidence.

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No-Fault Divorce… what is it?

There has been a lot of hype around the recently passed “No-Fault” divorce law which amended § 170 of New York’s Domestic Relations Law (DRL).  But what does this mean to the average Joe (or Josette) who just wants to get divorced?

The change added a new ground for divorce as DRL §170(7) which provides as follows:

§ 170. Action for divorce. An action for divorce may be maintained by
a husband or wife to procure a judgment divorcing the parties and
dissolving the marriage on any of the following grounds:
[...]
* (7) The relationship between husband and wife has broken down
irretrievably for a period of at least six months, provided that one
party has so stated under oath. No judgment of divorce shall be granted
under this subdivision unless and until the economic issues of equitable
distribution of marital property, the payment or waiver of spousal
support, the payment of child support, the payment of counsel and
experts’ fees and expenses as well as the custody and visitation with
the infant children of the marriage have been resolved by the parties,
or determined by the court and incorporated into the judgment of
divorce.
* NB Effective October 12, 2010

This effectively means that if one of the spouses makes an affidavit that states the marriage has been irretrievable broken for a period of at least six months, that can serve as grounds for divorce.  No more people lying on the stand about how horrible his or her spouse was, and thus, no more need to prove that the death of the marriage was the FAULT of one party or the other.  Oh happy day!

So what are the potential issues with this?  As of today, nobody really knows how this is going to work!  Because this is listed as another of the potential grounds for divorce, and the statute does not explicitly state that a party making this allegation is automatically entitled to a judgment of divorce, there are some attorneys and judges who believe that an action based on the new ground can be defended, and possibly defeated in a grounds trial, just like any other alleged ground for divorce.  I foresee someone challenging this and appeals to be had in all four Departments of the State, likely going right up to the Court of Appeals (our highest court in New York).  How exactly does one prove that a marriage is irretrievable broken?  How about a judge requiring the parties to go through a Conciliation Proceeding to certify the marriage is irretrievably broken before granting a judgment of divorce?  Or perhaps marriage counseling would be required.  Would expert testimony be necessary to determine if there is any chance to salvage the marriage?   Maybe the simple affidavit attesting to the breakdown will be deemed irrefutable evidence of the breakdown.  We simply don’t know the answers to these questions yet.

Here’s an interesting observation… the statute set forth above does NOT state that the breakdown had to be in the six months immediately prior to a party filing for divorce.  The general statute of limitations on grounds for divorce (under most circumstances, but not all) is five years.  Conceivably, one could say that four years ago, the marriage had irretrievably broken down for a six month period and now I’d like my divorce please.  Ha!  That’s a fun thought!

So what about all the other mumbo-jumbo in the statute about “…shall not be granted unless…” and all the other things that have to happen before a judgment of divorce can be granted?  Well, I think it is basically superfluous nonsense, truth be told.  People will either have a settlement agreement and get the divorce, or the litigation will go something like this:

  1. Plaintiff files under DRL § 170(7) and attaches an Affidavit to his or her Summons with Notice.
  2. The Court can make Findings of Fact and Conclusions of Law that the Plaintiff is entitled to a judgment of Divorce…. BUT NOT GRANT the divorce yet.
  3. The custody, visitation, support, maintenance and equitable distribution aspects of the case can be settled or tried if necessary.
  4. Once the ancillary issues are tried or settled and a decision is rendered, they can be incorporated into a Judgment which would THEN be granted, and the statute is therefore complied with, no sweat off anybody’s back.

So,where does that get us?  I think the Legislature has marched us into the 21st century and brought the last State in the Union inline with the other 49 by removing the necessity of lying under oath (not that anyone would ever do such a thing…) to get free of his or her annoying/abusive/aggravating/[insert adjective of your choice here] spouse.

In terms of real impact on the average divorce proceeding, I’m not sure it will have much of any.  The people who previously used the fault requirement to hold a spouse over the barrel in a little situation I like to think of as legalized blackmail (mean spouse would challenge grounds and push for a grounds trial unless the other spouse agreed to take less of the marital assets, in which case mean spouse would agree not to challenge grounds and divorce would sail through) will probably do the exact same thing under the new law.  The first few cases (I predict they will occur primarily in the New York City area) will likely be appealed and determine exactly how these things will work.  As of today, nobody can say for sure.  But in the other 90% of divorce proceedings, the new law will not be much more than words on a piece of paper.

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New York Finally Passed No-Fault Divorce Law

The text of the new law can be found at Laws of New York.

§ 170. Action for divorce. An action for divorce may be maintained by
a husband or wife to procure a judgment divorcing the parties and
dissolving the marriage on any of the following grounds:

(…)

* (7) The relationship between husband and wife has broken down
irretrievably for a period of at least six months, provided that one
party has so stated under oath. No judgment of divorce shall be granted
under this subdivision unless and until the economic issues of equitable
distribution of marital property, the payment or waiver of spousal
support, the payment of child support, the payment of counsel and
experts’ fees and expenses as well as the custody and visitation with
the infant children of the marriage have been resolved by the parties,
or determined by the court and incorporated into the judgment of
divorce.
* NB Effective October 12, 2010

And THAT, is New York’s version of “No-Fault” divorce, which goes into effect on October 12, 2010.

Doesn’t look like much, does it?

The real meat of the statutes passed by the legislature on August 13, 2010 was the maintenance, attorney’s fees, and expert fees provisions.

But I will get to those in another post.

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New York’s “No Fault” Divorce Bill

It seems that every year, the New York Legislature tries, and fails, to pass a “No-Fault” divorce bill.

This year is no different.  There have been different versions running around the Assembly and the Senate, both known as the Divorce Reform Act of 2010 (Assembly Version versus Senate Version).

The long and short of it is this:

  1. There will be a new ground for divorce in New York (to be set forth in Domestic Relations Law (DRL) § 170 (7)) as being :”The relationship between Husband and Wife has broken down irretrievably for a period of at least six months, provided that one party has so stated under oath.”  This amounts to “no-fault” inasmuch as it does not require one party to prove fault on the part of the other, as has traditionally been required in New York.
  2. There is a new provision providing for the formulaic calculation of Temporary Maintenance awards amending DRL § 236-B.
  3. In order to opt-out of the statutory formula, a specific statutory waiver must be included in the order or agreement similar to that used to opt-out of the Child Support Standards Act (CSSA).
  4. There are additional considerations enumerated for the Court to look at, including one that may bring enhanced earnings claims (O’Brien claims) within the terms of the statute.
  5. There would be a rebuttable presumption that counsel fees are to be awarded to the less-monied spouse, on a timely basis, pendente lite.

So what does all that mean in English?  It means that New York State is trying to move into the 20th Century (NOTE:  the rest of the world currently lives in the 21st Century) in terms of divorce law.

The most interesting part of the proposed legislation is perhaps the formula propounded by the legislature to determine temporary maintenance (that’s alimony to the rest of the world).  The calculation goes something like this:

  1. Take 30% of the monied spouse’s adjusted gross income and subtract from it 20% of the non-monied spouse’s adjusted gross income (adjusted gross income is defined in the bill similar to the definition set forth in the CSSA).
  2. Multiply the adjusted gross income of the monied spouse by 40% and subtract from this sum the non-monied spouse’s adjusted gross income.
  3. Choose the lesser of the two sums from numbers 1&2 and that is your presumptively correct amount of temporary maintenance.
  4. The above applies up to an income cap of $500,000 (as if anyone in Western new York will need to worry about that).
  5. The duration of the temporary maintenance is to be determined by the Court “…by consideration of the length of the marriage.”  (please don’t ask, because I don’t know what that means).
  6. If the Court finds the presumptively correct amount of maintenance to be unjust or inappropriate, the Court can deviate from the presumptively correct amount by considering any or all of 17 enumerated factors and setting forth in a written Order the presumptively correct amount, the factors it considered in adjusting that amount, and the reasons why it adjusted that amount.  (The written findings cannot be waived by the Court, the parties, or the attorneys).
  7. The parties can opt-out of the presumptively correct amount in a written agreement or oral stipulation so long as it includes certain waiver language set forth in the statute.

And the question everyone is going to want the answer to:  Will this new legislation give me a change in circumstances sufficient to go back and get my maintenance changed?  NO!  The text of the bill specifically states that it will not.

One of the more interesting provisions of the bill, (in my humble opinion) is the fact that it directs the Court to consider “The contributions and services or the party seeking temporary maintenance as a spouse, parent, wage earner, and homemaker and to the career or career potential of the other party.”

This seemingly brings the enhanced earnings claims (which have been a creature of case-law under O’Brien and its progeny) into the realm of statute and with one stroke of the pen changes the nature of an enhanced earnings claim from equitable distribution to maintenance.  The biog deal here is that distributive awards are not taxable, but maintenance is includable as income to the person receiving it and deductable to the person paying it.  I’m interested to see what will become of this if the bill is ever signed into law; which brings us back to my original comments…

The State of New York still has no “No-Fault” divorce law and the Governor has not, as of this date, signed the Divorce Reform Act of 2010 into law.

Knock Knock… Whose there?

No-fault divorce… No-fault divorce who?

No-No-fault divorce in New York, that’s who!

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“No-Fault” Divorce: The Holy Grail

In New York State, one must have “Grounds” to obtain a divorce.

Grounds for divorce are set forth in our Domestic Relations Law Section 170  and include only:

  1. Cruel and Inhuman Treatment -  A “catch all” that is often abused and sometimes misused;
  2. Abandonment – for more than one year…  may also encompass “constructive abandonment”  a/k/a refusal of sexual relations;
  3. Confinement of Defendant to prison – self explanatory;
  4. Adultery – which is surprisingly difficult to prove since spouses are incompetent to testify against each other concerning this; or
  5. Parties have lived apart pursuant to a judgment of separation or separation agreement for at least one year-  sometimes referred to as a “conversion” divorce.

In order to obtain a divorce in New York, only one of the above grounds will do the trick, nothing else.  The party seeking the divorce must prove, to a jury if necessary, that he or she has sufficient grounds for divorce.  And the longer parties are married, the greater the proof necessary to demonstrate sufficient grounds.  Simply saying “We don’t get along any more and we both want a divorce” is insufficient.

To complicate matters, if there are no grounds for divorce, there can be no equitable distribution of property.  What does that mean in English?  It means that if Wife Wanda files for divorce against Husband Bob, and Bob has a great job, lots of income, and all the assets are in his name, and Wanda has little more than her dislike of Bob’s bottle collection as her grounds, Bob gets to have a trial and challenge her to prove her grounds.  But why would Bob want to do that, you might say?  Because if Bob defeats Wanda in a grounds trial, he will not be forced to give her any of the money he has hidden away in a Swiss bank account, or to give her the house owned in his name, or to provide her with the Mustag GTO that he just bought while leaving her with the ’82 Camry.  Bob can effectively hold Wanda over the economic barrel.  When this happens, Wanda is usually willing to give up what would normally be her fair share of the assets in exchange for Bob not challenging her grounds for divorce.  I tend to think of this as legalized blackmail, but perhaps that is being too harsh…

You may have noticed there is no “irreconcilable differences” in that list of grounds.  New York is, I believe, the only state in the union that does not have a “no-fault” divorce provision, such as irreconcilable differences.  There is an outdated mode of thought in New York that the State has a vested interest in the marriage relationship.  Personally, I feel that vested interests in marriage are strictly the business of the people involved in that marriage and the State has no business forcing two people who can’t stand each other to remain together.  I leave it to religion to make moral determinations, those ar enot for me.

There has been a push in the past decade to bring New York in line with the rest of the country and provide a no-fault ground for divorce, but a law has yet to pass.  There is currently a bill in the New York State Assembly which would add “irreconcilable differences” to the list of grounds for divorce.  I am all for it!  The time has come for New York to get in line with the rest of the country and give people a way out when the love is gone and there is no going back.

A grounds trial is a horrific beast to watch.  I’ve seen them, and they are not pretty.  The plaintiff parades a line of witnesses across the stand to say what a horrible creature the defendant is.  The defendant parades a line of witnesses across the stand to say what a wonderful person he or she is and explain away the allegations of the plaintiff.  In the process, both people are irrevocably scarred, any chance of dealing civilly with the other is burnt to ash, and the State has thus preserved the “sanctity” of marriage.

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