A Manhattan appeals panel has reversed a trial court’s grant of divorce, holding that the wife’s allegations did not satisfy New York’s “cruel and inhuman treatment” standard, notwithstanding her claim that her husband “physically force[d] himself on [her] sexually.”

“In its vagueness and generality, this testimony could include conduct ranging from the criminal (e.g., forcible rape) to the merely obnoxious,” the unanimous Appellate Division, 1st Department, panel held in its unsigned opinion, Gross v. Gross, 256.