New York Court of Appeals
Grace M. Lake, Respondent v. L. Frank Lake, Appellant
January 26, 1909194 N.Y. 179
Summary
The New York Court of Appeals reversed the lower court's order requiring the husband to pay counsel fees to the wife for a motion to set aside a divorce judgment, holding that the statutory power to award such fees exists only while the marital relationship persists and the wife must show necessity and lack of means, which she failed to do.