Matter of Seide v. Dickerson

2025 NY Slip Op 04252 · Appellate Division, Second Department · July 23, 2025 · No. 2023-08984

Summary

This Appellate Division, Second Department decision reviews a Family Court order that denied a father's petition for parental access to his child. Applying the best interests of the child standard and deferring to the Family Court's factual findings, the appellate court affirmed the denial, finding a sound and substantial basis in the record that access would be detrimental to the child. The court concluded that absent extraordinary circumstances, parental access privileges cannot override the child's well-being.

Court
Appellate Division, Second Department
Writing for the Court
Lara J. Genovesi, J.P.; William G. Ford; Laurence L. Love; Donna-Marie E. Golia, JJ.
Jurisdiction
New York
Decision date
July 23, 2025
Docket number
2023-08984
Procedural posture
Appeal from an order of the Family Court, Queens County denying the father's petition for parental access.
Standard of review
Review for abuse of discretion; the family court's findings are upheld if they have a sound and substantial basis in the record.
Precedential value
published
Parties
James Dickerson v. Margaret Seide
Disposition
affirmed

Topics

family lawparental rightschild custodyvisitation

Practice areas

family law

Questions Presented

  1. Whether the Family Court's denial of parental access was supported by a sound and substantial basis and therefore should be affirmed.

Holdings

  1. The Family Court's determination that parental access would be detrimental to the child has a sound and substantial basis in the record; the order is affirmed.

Key quotations

[T]he Family Court has broad discretion in fashioning a remedy in matters of custody and [parental access], with the paramount concern being the best interests of the child.
Absent extraordinary circumstances, where [parental access] would be detrimental to the child's well‑being, a noncustodial parent has a right to reasonable [parental access] privileges.

Factual background

James Dickerson, the noncustodial father, sought parental access to his child. The Family Court found that such access would be detrimental to the child's well‑being and denied the petition. Dickerson appealed that determination.

Procedural history

The father appealed the Family Court's order dated May 1, 2023, which denied his petition for certain parental access with the child.

Court Document

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