Despite its recognition of the “frustration” among matrimonial attorneys regarding New York’s continued status as the only state in the country without no-fault divorce, a Brooklyn appellate panel has declined to broaden the grounds for divorce by recognizing a “social abandonment” cause of action.

Plaintiff Novel Davis argued that her husband Shepherd Davis’ refusal to eat meals with her, celebrate holidays together or attend family functions should be recognized as a form of abandonment, one of the four grounds for divorce in contested New York proceedings.

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