In a custody decision, a New York appellate court affirmed a lower court’s decision to grant a mother sole custody of the parties’ child. In this particular case, the parties were divorced in 2001, and for several years thereafter shared joint custody of their daughter. The mother had primary physical custody subject to liberal unsupervised visitation with the father. The mother moved for sole custody, requesting that the father’s visitation be suspended, or alternatively, that it be supervised. The father cross-moved for sole legal and physical custody, claiming that the mother was interfering with his visitation.