Child custody; Parenting time; Whether there was "proper cause" or a "change of circumstances"; Shade v. Wright; Vodvarka v. Grasmeyer; Whether there was an "established custodial environment"; MCL 722.27(c); Pierron v. Pierron; LaFleche v. Ybarra; The 12 statutory best-interest factors; MCL 722.23; Eldred v. Ziny; Whether there was proper communication and cooperation between the parents; MCL 722.23(j); Consideration of the parties’ finances; Dempsey v. Dempsey; Whether a trial court’s decision as to a best-interest factor is against the great weight of the evidence; MCL 722.28; Presumption that a trial court knows the law; Charles A. Murray Trust v. Futrell; Harmless error; Kubicki v. Sharpe; Kessler v. Kessler; Mootness; B P 7 v. Bureau of State Lottery; Abandoned issue; Houghton v. Keller

[Unpublished opinion.] The court held that the trial court did not err by granting the defendant-mother’s motion for a modification of parenting time with the parties’ children. The parties had joint legal and physical custody, as well as a parenting time agreement under which the children stayed overnight with the plaintiff-father on Thursday evenings and every other weekend. Two years into the arrangement, defendant filed a motion to modify parenting time, claiming there were issues with the arrangement and overnight parenting time with plaintiff during the school year was not in the children’s best interests. The trial court ordered that, during the school year, plaintiff would have alternating weekends with the children and parenting time on Wednesday nights, and that defendant would generally have the remainder of the time with the children. It also ordered that, during the summers, the parties would each receive an uninterrupted two-week block of time and would otherwise receive alternating weeks with the children. On appeal, the court found that the trial court did not abuse its discretion it weighing the best interest factors. “The trial court found that three factors favored [defendant] and that six factors were equal.” Factor (k) “was not an issue, and the court did not indicate whether factors (i) and (l) favored either party.” Based on its best interest analysis, “the trial court found by clear and convincing evidence that it was in the minor children’s best interests to change their custodial environment. That finding was not ‘so palpably and grossly violative of fact and logic that it evidences a perversity of will, a defiance of judgment, or the exercise of passion or bias’ as required for us to conclude that the trial court’s decision was an abuse of discretion.” The court also found that although “the trial court’s ruling that it would not consider matters at issue before the date of the ‘last effective order’” was erroneous, the error was harmless. Finally, it rejected plaintiff's argument that the trial court was biased against him. Affirmed.