Miller v. Miller 156 A.D.2d 164, 548 N.Y.S.2d 209 (1st Dept. 1989) Former wife sued former husband for arrearages in payments required to be made under divorce decree. The Supreme Court, New York County, Saxe, J., denied former wife's motion for summary judgment in part, and former wife appealed. The Supreme Court, Appellate Division, held that issues of fact, precluding summary judgment, existed as to whether wife had waived rights to payments for certain prior years by not making demand therefor since 1978. Klebanow v. Klebanow 133 A.D.2d 553, 519 N.Y.S.2d 286 (1st Dept. 1987) The Appellate Division, First Department sustained a wife's claim to a constructive trust over pre-marital real property although the wife had not contributed funds to the property, she had invested substantial effort which could satisfy the "transfer in reliance" element of a constructive trust.