Divorce; Motion for reconsideration; MCR 2.119(F)(3); Failure to present new arguments or identify an error by which the trial court was misled; Motion for sanctions & attorney fees; MCR 1.109(E)(7) & 2.625(A)(2); MCL 600.2591(1); A frivolous clam or defense; MCL 600.2591(3)(a)(i)-(iii); Attorney fees in a domestic relations case; MCR 3.206(D); Requirement that a motion under the rule be brought within a reasonable time

Holding that the trial court did not abuse its discretion in denying defendant-ex-husband’s motion for reconsideration or his motion for sanctions and attorney fees in this divorce case, the court affirmed. Since their divorce, “the parties have engaged in extensive postjudgment litigation including multiple motions regarding parenting time, custody and child support.” Relevant here, defendant moved to modify parenting time and his child support obligation. Plaintiff-ex-wife filed objections to the referee’s recommendation. Before the trial court’s de novo hearing, “defendant filed a verified motion for sanctions and attorney fees. [He] set forth a history of allegedly frivolous filings by plaintiff throughout the postjudgment litigation, including the most recent litigation concerning child support.” He contended that her objections to the referee’s recommendation as to child support were frivolous and attributed “two adjournments to plaintiff providing disorganized and incomplete financial information.” He sought sanctions and attorney fees under MCR 1.109, MCL 600.2591, and MCR 3.206(D)(2). The trial court heard the motion at the same “hearing at which it modified the referee’s child-support recommendation. After ruling on plaintiff’s objections to the referee’s recommendation, the court denied defendant’s motion for sanctions and attorney fees, finding that plaintiff’s objections were not frivolous.” Defendant then unsuccessfully moved for reconsideration, asserting that the trial court did not articulate a reason for denying his attorney fee request. The court noted that this motion “did not present new arguments or identify an error by which the trial court had been misled.” Thus, under the circumstances, the trial court did not abuse its discretion in denying it. The court also held that the denial of his initial motion for sanctions and attorney fees was proper, noting that “plaintiff’s objections to the referee’s findings resulted in relief, i.e., a reduction in her calculated income of over $13,000[.]” Further, the court found no error in the denial of attorney fees under MCR 3.206(D).