In Matter of Williams v. Bentley, 26 AD3d 441 (2d Dept 2006) the Appellate Division held the Family Court improperly conducted a custody trial without the mother's lawyer and awarded custody to the father, after the mother requested a lawyer. Additionally, the Appellate Division held that requiring the mother to proceed without an attorney in the custody case "violated the mother's right to be represented by counsel." (Id at 441.) The Appellate Division reversed the decision and remanded the case to Family Court.