In Gleason v. Gleason, 26 N.Y.2d 28 (1970), the Court of Appeals heralded the benefits to society from the 1966 Divorce Reform Law, which repealed New York’s “ancient divorce laws, which for almost 200 years [] sanctioned divorce solely for adultery.” Among the new grounds was the conversion divorce based on living apart for more than one year following a written and acknowledged agreement—New York’s closest brush with no-fault divorce:
Implicit in the statutory scheme is the legislative recognition that it is socially and morally undesirable to compel couples to a dead marriage to retain an illusory and deceptive status and that the best interests not only of the parties but of society itself will be furthered by enabling them to extricate themselves from a perpetual state of marital limbo.
