Since 2010, a new ground has been added, effectively permitting no-fault divorce in New York state: The relationship between husband and wife has broken down irretrievably for a period of at least six months (DRL §170.7)
http://www.cbn.com/cbnnews/us/2010/july/new-york-to-adopt-no-fault-divorce-bill/?mobile=false
http://www.livestrong.com/article/100998-states-fault-divorce/