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Do women have to show a pattern of abuse in order to receive a favorable disposition of property?

That’s hard to prove. While a woman does not have to show a pattern and practice of abuse, she may have to show more than one isolated incident of cruelty. In one case, for example, a court could consider, but not give "undue weight" to, a husband’s "occasional" violence during arguments. On the other hand, another case held that requiring a "systematic pattern of abuse" would be error.