Matter of Sheena D

In Matter of Sheena D. (8 NY3d 136 [2007]) the Court held, inter alia, that in the context of a Family Court Act article 10 proceeding, the trial court must conduct periodic review of an order of protection to determine whether or not continuance of the order of protection is in the best interest of a subject child. In Sheena D. (supra), the Court of Appeals held that an order of protection issued in an article 10 proceeding may not extend beyond the order of fact-finding and disposition, although supervision over a case and, consequently, possible extension of an order of protection, may take place after meaningful periodic review. In Sheena D., the Court of Appeals found that permitting the existing order of protection would intrude upon the respondent parent's rights in that case.