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Allen v. Farrow
New York Supreme Court, Appellate Division
197 A.D.2d 327 (1994)
In 1980, Woody Allen (plaintiff) and Mia Farrow (defendant) began a romantic relationship. At the beginning of the relationship, Allen showed little interest in forming bonds with Farrow’s seven children. In 1985, Farrow adopted an eighth child, Dylan O’Sullivan Farrow. Allen then began developing a relationship with Dylan and one of Farrow’s other children, Moses Farrow. In 1986, Farrow became pregnant with Allen’s child and later gave birth to a baby boy, Satchel Farrow. Around 1990, Farrow expressed concerns about Allen’s relationship with Dylan, and Allen expressed concerns about Farrow’s relationship with Satchel. In 1991, Allen adopted Dylan and Moses. Around the time of the adoption, Allen’s sexual relationship with Farrow’s child who had reached the age of majority, Soon-Yi Previn, became known. The relationship between Allen and Previn increased Farrow’s concerns that the relationship between Allen and Dylan may be sexual in natural. A custody dispute regarding Moses, Dylan, and Satchel then commenced in the Individual Assignment System of the New York Supreme Court. During the custody proceeding, Allen denied that his relationship with Dylan was sexual, and no conclusive evidence of sexual abuse was presented. However, Dylan had clear signs of emotional issues, which required therapy. Evidence was also presented that Allen had continued his relationship with Previn despite the adverse effects it had on the family and had displayed sexual photos of Previn around his home, causing confusion among the children. The court granted Farrow custody of the children and denied Allen’s unsupervised visitation requests based on the best interests of the children. In doing so, the judge stated that even if Allen had not sexually abused Dylan, she was clearly affected by the investigation into the abuse and that if granted unsupervised visitation with the children, Allen would expose the children to his relationship with Previn. Allen appealed.
Rule of Law
Holding and Reasoning (Ross, J.)
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