New York Law Journal, November 25, 2025 —
As a divorce lawyer, sometimes the effort to find a continuing legal education (CLE) program that will expand your intellectual horizon in a way that can be beneficial to your actual divorce practice can feel daunting. There is no shortage of programs available. However, to create a program that is educational and practical is no small task.
Which is why it is so refreshing when a decision of interest is released in the matrimonial arena that, to a large degree, has all the bells, whistles, and other intangible “it” factors that make for a memorable CLE program.
That brings us to the Honorable Jeffrey S. Sunshine’s recent decision in T.I. v. R.I., 2025 NY Slip OP 51575 (U), which is to my mind a primer on the meaning of the following objection often heard at matrimonial and other trials when a witness is being cross-examined, namely, “Objection. Beyond the scope of direct examination.”
Let me start by saying that the subject matter of the case itself is serious in nature. While this article will focus on trial practice, it should be noted that T.I. is, sadly, a particularly arduous matter. The first divorce action—“extremely contentious litigation”—ended via discontinuance after a purported reconciliation. In the second (current) action for divorce, the plaintiff-wife filed an order to show cause seeking a civil order of protection against the defendant-husband.
In her motion, the wife detailed “numerous incidents of allegations of domestic violence and asserted that ‘[d]efendant also subjected me to sexual abuse, coercive control, financial abuse, and verbal abuse and harassment on an ongoing basis’.” The decision notes that “there is no specific allegation to rape in plaintiff’s affidavit in support of her application or to any allegations related to any December 2019 incident which is the subject of the pending criminal action against defendant-father.”