Jackie Gleason v. Genevieve Gleason

[26 N.Y.2d 28 Page 32] In 1966, the Legislature repealed this State's ancient divorce laws -- which for almost 200 years had sanctioned divorce
solely for adultery -- and enacted the Divorce Reform Law (L. 1966, ch. 254, eff. Sept. 1, 1967) authorizing divorce on other
grounds (Domestic Relations Law, § 170). In addition to four grounds based on "fault," new section 170 of the Domestic Relations
Law specified two "nonfault" grounds predicated on a couple's living apart for a period of two years after the granting of
a separation judgment or decree (subd. [5]) or the execution of a written separation agreement [26 N.Y.2d 28 Page 33]