People ex rel. Foote v. Stancari

Assuming arguendo that the instant proceeding has not been rendered academic by reason of the petitioner’s completion of his jail sentence (see, Matter of Williams v Cornelius, 76 NY2d 542; but see, Matter of Madison County Support *836Collection Unit v Drennan, 156 AD2d 883; Ward v Ward, 71 AD2d 854), we find his contentions to be without merit. A Hearing Examiner clearly has the authority to conduct a willfulness hearing pursuant to Family Court Act § 454 (see, Family Ct Act § 439 [a]), and the record fails to demonstrate that the petitioner raised any issue requiring a de novo willfulness…