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In Powers v. Powers, 86 NY2d 63, 629 NYS2d 984, 653 NE2d 1154 (1995), the New York State Court of Appeals set forth the law governing the burden of proof upon the issue of “willfulness” in support enforcement proceedings where the court is asked to commit the defaulting party to jail. That opinion, which initially arose out of a support enforcement application that had been brought before the Family Court, has since been widely cited by matrimonial justices throughout our state in support of contempt findings. While the final paragraph of that opinion had the potential for becoming the veritable pot of gold at the end of the support enforcement rainbow, it appears to have gone largely ignored by the marital bar.

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