The following excerpt is from Blair v. Blair, 204 Misc. 58 (N.Y. Fam. Ct. 1953):
In the case of Sternheim v. Sternheim (174 Misc. 574) this court said: "To permit a spouse to leave her husband and to allow the obligation for her support to continue, despite her leaving him, the court must find as a matter of fact that it is impossible or unsafe for the spouse to continue to live with her husband." An isolated disagreement is not sufficient on which a finding of a constructive abandonment can be predicated. The disagreements here were continuous. While there is no testimony of vocal disagreements, the conduct between the parties undoubtedly establishes disagreement of serious nature.