reasoned analysis in New York

2022"The court need not analyze and apply each and every factor set forth in the statute, but must provide a reasoned analysis of the factors it ultimately relies upon in awarding maintenance" ( Robinson v Robinson , 133 AD3d 1185, 1186 [2015] [internal quotation marks and citations omitted]; see Hartog v Hartog , 85 NY2d 36, 51 [1995]).

2018While "[t]he court need not analyze and apply each and every factor set forth in the statute," it "must provide a reasoned analysis of the factors it ultimately relies upon in awarding maintenance" ( Robinson v Robinson , 133 AD3d 1185, 1186 [2015] [internal quotation marks and citation omitted]; see Sprole v Sprole , 145 AD3d 1367, 1368 [2016]).

2022The court's decision provided a reasoned analysis for deviating from the presumptive maintenance amount and, therefore, the court's determination will not be disturbed ( see Curley v Curley , 125 AD3d 1227, 1228-1229 [2015]; Van Dyke v Van Dyke , 273 AD2d 589, 594 [2000]; Walters v Walters , 252 AD2d 775, 775 [1998]; Orlando v Orlando , 222 AD2d 906, 908 [1995], lv dismissed and denied 87 NY2d 1052 [1996]).

2020Although the court does not have to analyze every factor set forth in Domestic Relations Law § 236 (B) (former [6]), it must give a reasoned analysis for its ultimate determination ( see Johnston v Johnston , 156 AD3d 1181, 1184 [2017], appeal dismissed 31 NY3d 1126 [2018], lv denied 32 NY3d 1053 [2018]; Curley v Curley , 125 AD3d 1227, 1228 [2015]).

2016The court must set forth a reasoned analysis of the factors it relies upon in fashioning the award, “but it ‘is not required to analyze and apply every factor set forth in [the statute]’ ” (Curley v Curley, 125 AD3d 1227, 1228 [2015], quoting McAteer v McAteer, 294 AD2d 783, 784 [2002]; see Robinson v Robinson, 133 AD3d at 1186 ).

2015The court need not analyze and apply each and every factor set forth in the statute, but “must provide a reasoned analysis of the factors it ultimately relies upon in awarding maintenance” (Curley v Curley, 125 AD3d 1227, 1228 [2015]; see Vantine v Vantine, 125 AD3d 1259, 1261 [2015]; McAteer v McAteer, 294 AD2d 783, 784 [2002]).

2023Although the court need not articulate every factor it considers, it must provide a reasoned analysis of the factors it relies upon ( see Pfister v Pfister , 146 AD3d at 1137 ).

2022Although "[t]he court need not articulate every factor it considers, . . . it must provide a reasoned analysis of the factors it ultimately relies upon in [determining] maintenance" ( Pfister v Pfister , 146 AD3d 1135, 1137 [2017] [internal quotation marks and citations omitted]; see Domestic Relations Law § 236 [B] [6] [e] [1]).

2022"The court need not analyze and apply each and every factor set forth in the statute, but must provide a reasoned analysis of the factors it ultimately relies upon in awarding maintenance" ( Robinson v Robinson , 133 AD3d 1185, 1186 [2015] [internal quotation marks and citations omitted]; see Hartog v Hartog , 85 NY2d 36, 51 [1995]).

2015The court must provide a reasoned analysis of the factors it ultimately relies upon in awarding maintenance, but it “is not required to analyze and apply every factor set forth in [the statute]” (McAteer v McAteer, 294 AD2d 783, 784 [2002]; see Hartog v Hartog, 85 NY2d 36, 51 [1995]; Quarty v Quarty, 96 AD3d 1274, 1277 [2012]; Freas v Freas, 33 AD3d 1069, 1071 [2006]; Wojewodzic v Wojewodzic, 300 AD2d 985, 986 [2002]).

2023Where there is a deviation from the presumptive amount reached by application of the relevant formula, the court should explain the reasons for that deviation ( see generally Severny v Severny , 210 AD3d 419 , 419 [1st Dept 2022]). "[T]he court need not analyze and apply each and every factor set forth in the statute," but it "must provide a reasoned analysis of the factors it ultimately relies upon in awarding maintenance" ( Gordon-Medley v Medley , 160 AD3d 1146 , 1147 [3d Dept 2018]; see Gutierrez v Gutierrez , 193 AD3d 1363, 1364 [4th Dept 2021]; Johnston v Johnston , 156 AD3d 1181, 1184 [

2022"The court need not articulate every factor it considers, but it must provide a reasoned analysis of the factors it ultimately relies upon in awarding or declining to award maintenance" ( Hughes v Hughes , 200 AD3d 1404, 1407 [2021] [internal quotation marks, brackets and citations omitted]; see Johnston v Johnston , 156 AD3d 1181, 1184 [2017], appeal dismissed 31 NY3d 1126 [2018], lv denied 32 NY3d 1053 [2018]).

2013The presumption of regularity assumes that statutory requirements, including those regarding service, were followed (see People v Dominique, 90 NY2d 880, 881 [1997]).

2013The presumption of regularity assumes that statutory requirements, including those regarding service, were followed (see People v Dominique, 90 NY2d 880, 881 [1997]).

2023"Although the court need not articulate every factor it considers, it must provide a reasoned analysis of the factors it ultimately relies upon in determining maintenance" ( King v King , 202 AD3d at 1384 [internal quotation marks, brackets, ellipsis and citations omitted]; see Domestic Relations Law § 236 [B] [6] [e] [1]).

2023"Although the court need not articulate every factor it considers, it must provide a reasoned analysis of the factors it ultimately relies upon in determining maintenance" ( King v King , 202 AD3d at 1384 [internal quotation marks, brackets, ellipsis and citations omitted]; see Domestic Relations Law § 236 [B] [6] [e] [1]).

2015The court must provide a reasoned analysis of the factors it ultimately relies upon in awarding maintenance, but it “is not required to analyze and apply every factor set forth in [the statute]” (McAteer v McAteer, 294 AD2d 783, 784 [2002]; see Hartog v Hartog, 85 NY2d 36, 51 [1995]; Quarty v Quarty, 96 AD3d 1274, 1277 [2012]; Freas v Freas, 33 AD3d 1069, 1071 [2006]; Wojewodzic v Wojewodzic, 300 AD2d 985, 986 [2002]).

2004While plaintiff correctly contends that Supreme Court must detail the factors it considered from Domestic Relations Law § 236 (B) (6) (a) and demonstrate a reasoned analysis for its decision (see Holterman v Holterman, 307 AD2d 442, 442 [2003], affd 3 NY3d 1 [2004]; Wojewodzic v Wojewodzic, 300 AD2d 985, 986 [2002]; McAteer v McAteer, 294 AD2d 783, 784 [2002]; Spenello v Spenello, 274 AD2d 822, 823 [2000]), it is not required to consider each statutory factor (see McAteer v McAteer, supra at 784; Wojewodzic v Wojewodzic, supra at 986).

2015The court need not analyze and apply each and every factor set forth in the statute, but “must provide a reasoned analysis of the factors it ultimately relies upon in awarding maintenance” (Curley v Curley, 125 AD3d 1227, 1228 [2015]; see Vantine v Vantine, 125 AD3d 1259, 1261 [2015]; McAteer v McAteer, 294 AD2d 783, 784 [2002]).

2015The court need not analyze and apply each and every factor set forth in the statute, but “must provide a reasoned analysis of the factors it ultimately relies upon in awarding maintenance” (Curley v Curley, 125 AD3d 1227, 1228 [2015]; see Vantine v Vantine, 125 AD3d 1259, 1261 [2015]; McAteer v McAteer, 294 AD2d 783, 784 [2002]).

2025We likewise find no abuse of discretion with the 40.5-month duration of the maintenance award, which is within the statutory guidelines and based upon a reasoned analysis of the relevant factors ( see Domestic Relations Law § 236 [B] [6] [f]; Harris v Schreibman , 200 AD3d at 1121 ).

2023Here, the court articulated each factor it considered, including the wife's testimony regarding domestic violence by the husband and that, because he removed the wife's access to their bank accounts, she was unable to pay for childcare or a vehicle. [FN3] Although the wife made references to domestic violence throughout the trial, her testimony detailed only one incident in particular. [FN4] Also, while the husband's actions may have impeded the wife's ability to secure employment, we cannot say that Supreme Court's decision not to deviate from the guidelines obligation constitutes an abuse of

2018Because the court considered the necessary factors, including the disparity in the parties' incomes, and provided a reasoned analysis of the factors it relied upon, we will not disturb the maintenance award ( see Barnhart v Barnhart , 148 AD3d at 1267-1268 ).

2017“The amount and duration of a maintenance award are addressed to the sound discretion of the trial court, and will not be disturbed provided that the statutory factors and the parties’ predivorce standard of living are considered” (Robinson v Robinson, 133 AD3d 1185, 1186 [2015] [citation omitted]; see Domestic Relations Law § 236 [B] [former (6) (a)]; Barnhart v Barnhart, 148 AD3d 1264, 1267 [2017]). 2 “The court need not articulate every factor it considers, but it ‘must provide a reasoned analysis of the factors it ultimately relies upon in awarding maintenance’ ” (Pfister v Pfister, 146 AD

2001We do find merit, however, in plaintiff’s contention that Supreme Court erred by failing to provide a reasoned analysis of its decision to not award her maintenance, as required by Domestic Relations Law § 236 (B) (6) (b) (see, Allen v Allen, supra, at 692 ; Maczek v Maczek, 248 AD2d 835, 837-838 ; cf., Nielson v Nielson, 259 AD2d 916, 917 ).

2000Analysis of the record in light of other statutory factors reveals a lack of proof regarding her assets, her ability to be self-supporting, including the need for career training, her mental and physical health, her nonmonetary contributions to the marriage and to plaintiffs career, all of which could have been employed by Supreme Court to make a reasoned analysis of her need for maintenance (see, Nielson v Nielson, 259 AD2d 916, 917 ).

2025Here, considering the relevant factors, as reflected in the record, including the lifestyle the plaintiff was used to during the purported marriage, the actual length of the purported marriage, the plaintiff's status as a stay-at-home mother during the relationship, and the plaintiff's current income of $49,000 per year, the court providently exercised its discretion in awarding the plaintiff maintenance in the amount of $2,440.59 per month for 55 months ( see Domestic Relations Law § 236[B][6][e][1]; Novick v Novick , 214 AD3d at 997; Kattan v Kattan , 202 AD3d 771, 776 ).

2025Preliminarily, both parties agree that the FAA applies to their present dispute ( see Wu v [*3]Uber Techs., Inc. , 43 NY3d 288 , 297-298 [2024] [analyzing challenge to arbitration award under FAA "[i]n this case, the parties agree that the arbitration agreement in Uber's January 2021 terms of use is governed by the Federal Arbitration Act (FAA)"]; Pezhman v Bloomingdales, Inc. , 215 AD3d 603, 603 [1st Dept 2023] [engaging in review of arbitration award under FAA where the parties' arbitration agreement required review under the FAA).

2025Preliminarily, both parties agree that the FAA applies to their present dispute ( see Wu v [*3]Uber Techs., Inc. , 43 NY3d 288 , 297-298 [2024] [analyzing challenge to arbitration award under FAA "[i]n this case, the parties agree that the arbitration agreement in Uber's January 2021 terms of use is governed by the Federal Arbitration Act (FAA)"]; Pezhman v Bloomingdales, Inc. , 215 AD3d 603 , 603 [1st Dept 2023] [engaging in review of arbitration award under FAA where the parties' arbitration agreement required review under the FAA).

2025Moreover, "[t]he court need not articulate every factor it considers, but it must provide a reasoned analysis of the factors it ultimately relies upon in awarding maintenance" ( Kiani v Kiani , 197 AD3d 1168, 1170 [internal quotation marks omitted]).

2023The court need not articulate every factor it considers, but it must provide a reasoned analysis of the factors it ultimately relies upon in awarding or declining to award maintenance" ( Louie v Louie , 203 AD3d 1520, 1521 [3d Dept 2022] [internal quotation marks and citations omitted]; see Giuliano v Giuliano , 203 AD3d 1473, 1474-1475 [3d Dept 2022]).

2023The court need not articulate every factor it considers, but it must provide a reasoned analysis of the factors it ultimately relies upon in awarding or declining to award maintenance" ( Louie v Louie , 203 AD3d 1520, 1521 [3d Dept 2022] [internal quotation marks and citations omitted]; see Giuliano v Giuliano , 203 AD3d 1473, 1474-1475 [3d Dept 2022]).

2023Where there is a deviation from the presumptive amount reached by application of the relevant formula, the court should explain the reasons for that deviation ( see generally Severny v Severny , 210 AD3d 419 , 419 [1st Dept 2022]). "[T]he court need not analyze and apply each and every factor set forth in the statute," but it "must provide a reasoned analysis of the factors it ultimately relies upon in awarding maintenance" ( Gordon-Medley v Medley , 160 AD3d 1146 , 1147 [3d Dept 2018]; see Gutierrez v Gutierrez , 193 AD3d 1363, 1364 [4th Dept 2021]; Johnston v Johnston , 156 AD3d 1181, 1184 [

2023"When a pendente lite award of maintenance is found at trial to be excessive or inequitable, the [trial c]ourt may make an appropriate adjustment in the equitable distribution award" ( Johnson v Chapin , 12 NY3d 461, 466 [2009] [citations omitted]; see Giannuzzi v Kearney , 127 AD3d 1350, 1351 [3d Dept 2015]).

2023"When a pendente lite award of maintenance is found at trial to be excessive or inequitable, the [trial c]ourt may make an appropriate adjustment in the equitable distribution award" ( Johnson v Chapin , 12 NY3d 461, 466 [2009] [citations omitted]; see Giannuzzi v Kearney , 127 AD3d 1350, 1351 [3d Dept 2015]).

2022Here, Supreme Court wholly adopted verbatim the husband's proposed findings of fact and conclusions of law, without articulating the factors it considered or providing a reasoned analysis for its rulings on the proposed findings of fact and conclusions of law. "[F]indings of fact submitted pursuant to CPLR 4213 (a) cannot constitute the decision of the court [as] mandated by Domestic Relations Law § 236 (B) (5) (g)" ( Capasso v Capasso , 119 AD2d 268, 269 [1986]; see Sadaghiani v Ghayoori , 83 AD3d 1309 , 1310 n [2011]; cf. Douglas v Douglas , 281 AD2d 709 , 714 [2001]).

2022Here, Supreme Court wholly adopted verbatim the husband's proposed findings of fact and conclusions of law, without articulating the factors it considered or providing a reasoned analysis for its rulings on the proposed findings of fact and conclusions of law. "[F]indings of fact submitted pursuant to CPLR 4213 (a) cannot constitute the decision of the court [as] mandated by Domestic Relations Law § 236 (B) (5) (g)" ( Capasso v Capasso , 119 AD2d 268, 269 [1986]; see Sadaghiani v Ghayoori , 83 AD3d 1309 , 1310 n [2011]; cf. Douglas v Douglas , 281 AD2d 709 , 714 [2001]).

2022Here, Supreme Court wholly adopted verbatim the husband's proposed findings of fact and conclusions of law, without articulating the factors it considered or providing a reasoned analysis for its rulings on the proposed findings of fact and conclusions of law. "[F]indings of fact submitted pursuant to CPLR 4213 (a) cannot constitute the decision of the court [as] mandated by Domestic Relations Law § 236 (B) (5) (g)" ( Capasso v Capasso , 119 AD2d 268, 269 [1986]; see Sadaghiani v Ghayoori , 83 AD3d 1309 , 1310 n [2011]; cf. Douglas v Douglas , 281 AD2d 709 , 714 [2001]).

2022Here, Supreme Court wholly adopted verbatim the husband's proposed findings of fact and conclusions of law, without articulating the factors it considered or providing a reasoned analysis for its rulings on the proposed findings of fact and conclusions of law. "[F]indings of fact submitted pursuant to CPLR 4213 (a) cannot constitute the decision of the court [as] mandated by Domestic Relations Law § 236 (B) (5) (g)" ( Capasso v Capasso , 119 AD2d 268, 269 [1986]; see Sadaghiani v Ghayoori , 83 AD3d 1309 , 1310 n [2011]; cf. Douglas v Douglas , 281 AD2d 709 , 714 [2001]).

2022The court's decision provided a reasoned analysis for deviating from the presumptive maintenance amount and, therefore, the court's determination will not be disturbed ( see Curley v Curley , 125 AD3d 1227, 1228-1229 [2015]; Van Dyke v Van Dyke , 273 AD2d 589, 594 [2000]; Walters v Walters , 252 AD2d 775, 775 [1998]; Orlando v Orlando , 222 AD2d 906, 908 [1995], lv dismissed and denied 87 NY2d 1052 [1996]).

2022The court's decision provided a reasoned analysis for deviating from the presumptive maintenance amount and, therefore, the court's determination will not be disturbed ( see Curley v Curley , 125 AD3d 1227, 1228-1229 [2015]; Van Dyke v Van Dyke , 273 AD2d 589, 594 [2000]; Walters v Walters , 252 AD2d 775, 775 [1998]; Orlando v Orlando , 222 AD2d 906, 908 [1995], lv dismissed and denied 87 NY2d 1052 [1996]).