In Matter of Melody M. v Robert M., the Court determined that an award of sole legal custody to the father was in the best interests of the child where the mother utilized Facebook to insult and demean the child, who was then 10 years old, by, among other things, calling him an "asshole." She testified without remorse that she did so because that is what "[h]e is," and she thought it was important for her Facebook friends to know this. The Appellate Division charitably stated that her testimony reflected a lack of insight as to the nature of her conduct toward her oldest child.
The full decision can be read at the following link:
http://www.courts.state.ny.us/reporter/3dseries/2013/2013_00959.htm