The examination and focus on mental health in the legal profession and beyond has been gaining ground for some time now. Before the pandemic, in March 2018, Joseph Milowic III of Quinn Emanuel Urquhart & Sullivan wrote a moving article in this Journal regarding depression in the practice of law and the importance of finding meaning in what we do. After the pandemic, mental health issues have certainly come to the forefront on a variety of levels. Edward Steinberg, president of the New York State Trial Lawyers Association, wrote an article in August 2020 also in this Journal emphasizing the need to bring the topic of mental health "out of the shadows." The mental health impact of coercive control in the home—on the victim-spouse and children who occupy that home—has also been a continuing source of discussion particularly during the pandemic when an alarming increase in domestic violence has been reported.

A recent decision from the First Department, Palmer v. Spadone-Palmer, 2021 NY Slip Op 00122 (1st Dept. 2021) illustrates a unique intersection between mental health considerations and matrimonial law. A parent's mental health may well come into play when custody is in dispute. Palmer is not a decision on custody. Rather, it addresses a matrimonial litigant's mental health on a purely financial issue—specifically, when and under what circumstances it is appropriate to modify a party's obligation to pay spousal support that was delineated in a settlement agreement.