Custody; Inconvenient forum; MCL 722.1207(2); Established custodial environment (ECE); Child’s best interests

The court determined that the trial court did not abuse its discretion by exercising its jurisdiction over the child. Also, because the evidence did not clearly preponderate in the opposite direction, the trial court properly found that the child had an ECE with plaintiff-mother. Finally, the trial court’s findings as to the best interests of the child overall were not against the great weight of the evidence. Thus, the court affirmed the trial court’s order granting the parties joint legal custody of their child, but granting primary physical custody to plaintiff. Defendant-father contended that “the trial court erred by exercising jurisdiction over the child because Michigan was an inconvenient forum, and Florida was a more appropriate forum.” The court held that the trial court considered the statutory factors and properly concluded that “the convenience of Michigan and Florida as forums was roughly equal, with a slight advantage to Michigan as the more convenient forum.” It also observed that “although the statute requires the trial court to consider the statutory factors before determining whether Michigan was an inconvenient forum, the trial court was not required by the statute to give the factors any particular weight.” Thus, it held “as did the trial court, that consideration of the factors did not reveal Michigan to be an inconvenient forum, nor did it reveal Florida to be a more appropriate forum.”