Under the American Rule, “attorneys’ fees and disbursements are incidents of litigation and the prevailing party may not collect them from the loser unless an award is authorized by agreement between the parties or by statute or court rule.” Matter of A.G. Ship Maintenance v. Lezak, 69 N.Y.2d 1, 5 (1986). Domestic Relations Law §237 is one such statute that provides for fees to be awarded to the less-monied spouse in matrimonial actions “as justice requires” in order to level the litigation playing field.
