People v. Hyler, 226 A.D.3d 1147, 208 N.Y.S.3d 742 (2024).  Participant ordered by probation officer to have no contact with husband until there had been “serious progress” in her efforts at rehabilitation and in making restitution. Participant violated for having contact with husband. The Court held that this probation condition was reasonably related to rehabilitation and compliance with probation. The Court further noted that Participant agreed to this condition as part of her plea bargain and the treatment court contract, which generally stated that she would successfully complete treatment court.

Cossio v. Marceno, 334 So.3d 696 (2022). Sweeping no-contact orders prohibiting defendants from making contact with their spouses indicate the fundamental right of marriage. The court noted that absent extraordinary circumstances, such orders are generally not upheld and must be narrowly tailored to the relevant governmental interests.