Divorce; The court’s jurisdiction; Appeal from a postjudgment order awarding or denying attorney fees & costs; MCR 7.203(A)(1); MCR 7.202(6)(a)(iv)

Concluding that plaintiff-ex-wife failed to present any issues that were properly before it, the court held that it lacked jurisdiction to address her claims of error. Thus, it affirmed the 2022 order appealed from, which awarded defendant-ex-husband attorney fees and costs. His jurisdictional challenge implicated its limited scope of jurisdiction under MCR 7.203(A)(1), and the court found “that none of plaintiff’s claims of error are reviewable in this appeal.” It noted that she “was first ordered to pay the underlying attorney fees and costs on” 11/24/21. When she did not do so, the trial court entered another order, directing her “to issue a check or money order for the attorney fees and costs that day and mail it to defense counsel by the following evening. Plaintiff again failed to comply, leading to entry of the” 3/14/22 order appealed from here. Each order “contained an explicit award of attorney fees, albeit the same fees arising from plaintiff’s frivolous motion practice, and each was a final order as defined in MCR 7.202(6)(a)(iv), appealable by right under MCR 7.203(A)(1).” The court noted that when “‘a final order is entered, a claim of appeal from that order must be timely filed. A party cannot wait until the entry of a subsequent final order to untimely appeal an earlier final order.’” In this case, as plaintiff failed to appeal the initial “2021 order awarding attorney fees, any argument regarding the trial court’s reason for awarding sanctions or the reasonableness of those fees” was not reviewable. Rather, the court’s jurisdiction was “limited to issues specifically pertaining to the [3/14/22] order, which was entered well after the underlying attorney fees had been awarded in a final order that was not appealed.” The court determined that her 14 stated issues could be categorized into 5 claims of error. Only the fourth related “specifically to the order appealed, and even that issue does not address the award of attorney fees and costs therein[.]” The second and third ones related “to the initial award of attorney fees, and the first issue has a tangential relation to the attorney fees in that it speaks to whether plaintiff’s motions were frivolous. Even so, these issues” were not within the court’s limited jurisdiction because she did not appeal the “2021 order containing the initial award of attorney fees. The last issue is not remotely germane to any of the orders awarding attorney fees” and was also not reviewable here.