Matter of Erin G

In Matter of Erin G. (139 A.D.2d 737 [2d Dept 1988]) the respondent was found to have abused his 3 1/2-year-old daughter. On disposition, the Family Court issued an order of protection lasting until the child's 18th birthday. On appeal, the respondent argued that the length of the order of protection constituted unduly harsh punishment. The Appellate Division found that the question was governed by Family Court Act 1056 and that, although the period of time the order was to be in effect was "rather extensive," Family Court Act 1056 contained "no specification as to the duration of such orders." (At 739.) At the time Matter of Erin G. was decided, Family Court Act 1056 (1) did not limit the duration of an order of protection. However, subsequent to the decision in Matter of Erin G., Family Court Act 1056 (1) was amended to add the current language, "such order of protection shall remain in effect concurrently with, shall expire no later than the expiration date of, and may be extended concurrently with, such other order made under this part." (L 1989, ch 220, 1.)