On October 12, 2010, New York passed their version of “no-fault” divorce. Prior to this controversial, statutory change, New Yorkers had to prove grounds in order to obtain a divorce. In situations in which one party asserted grounds for divorce but the other party successfully defended such a claim at trial, the divorce would not be granted and the parties would remain married. After the new no-fault divorce option was added, instead of asserting grounds, those seeking a divorce could instead state that their marriage was “irretrievably broken” for a period of six months. However, the question remained as to whether a court had to simply accept one party’s contention that the marriage was irretrievably broken or if the court had the power to order a trial in order to make such a determination.