Rachel Anglin v. Harold Anglin

Summary

The New York Court of Appeals affirmed that a separation action does not terminate the marital economic partnership and therefore does not stop the accrual of marital property under Domestic Relations Law §236(B)(1)(c); the cutoff occurs only with a divorce action or a separation agreement. The Court rejected the plain‑meaning argument that a separation action is a "matrimonial action" for this purpose, emphasizing statutory harmony and legislative intent. A dissent argued that the majority’s view contradicts the economic partnership doctrine and the plain language of the statute.