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For decades, New York resisted no-fault divorce. It sat by as first California and then every other state adopted a statute allowing couples to divorce without proof of a specified form of marital fault. But in 2010, the state adopted a true no-fault provision, which allows divorce based on irretrievable breakdown. With new laws come questions, which New York courts must answer. A recent decision continues that process with a ruling on no-fault divorce and residency requirements, which may seem pedestrian, but which reflects longstanding controversy between states over the leniency of divorce laws and New York’s unique role in this history.



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