Child custody; The trial court’s findings of fact; Rittershaus v Rittershaus; Established custodial environment; MCL 722.27(1)(c); Bofysil v Bofysil; Best-interest factors; MCL 722.23; Factors (d), (f), (g), (h), & (l); Burden of proof; In re Anjoski; Parental presumption; MCL 722.25(1); Child Custody Act (CCA)

The court held that the trial court did not err in its custody decisions as to the parties’ four children. After the parties’ divorce, defendant-mother’s family members sought custody of their four children. In 2014, plaintiff-Williamson successfully petitioned for custody of BF and KF. In 2015, plaintiff-Heinz successfully obtained custody of LF2, and mother’s parents (plaintiffs-Greg and Nicole Morin) were granted custody of LF1. In 2021, defendant-father sought sole legal and physical custody of the children. During this process, Greg died, and Nicole, who was having health issues, agreed that mother should have custody of the children. The trial court ultimately granted sole physical custody of LF1 to mother, and granted father and mother joint legal custody. However, it granted Williamson sole physical custody of BF and KF, and granted mother, father, and Williamson joint legal custody. It also granted sole physical custody of LF2 to Heinz, and granted mother, father, and Heinz joint legal custody. On appeal, the court first rejected father’s argument that the trial court failed to make adequate factual findings concerning the best-interest factors. “While some of the trial court’s findings may appear brief to father, the entirety of the record reveals that the trial court gave each party ample opportunity to present their case and intently listened and then issued its findings and ultimate ruling.” It next rejected his challenge to the trial court’s custody decision as to LF1, noting that, “[g]iven the record evidence, father failed to establish by clear and convincing evidence that it was in LF1’s best interests to grant him sole legal and physical custody. Clear and convincing evidence established joint legal custody was in LF1’s best interests and sole physical custody with mother was in LF1’s best interests.” The court also rejected his challenge to the trial court’s custody decision as to LF2, BF, and KF, noting the trial court “was aware of the parental presumption contained in MCL 722.25(1), and that Williamson and Heinz were required to establish by clear and convincing evidence that custody in their favor was proper.” It found they met that requirement. The court then explained that “unlike cases involving termination of parental rights, which require the balancing of the best interests of the children with a parent’s constitutional rights, the CCA requires trial courts to focus on the children ‘to promote the best interests of the child and to provide a stable environment for children that is free of unwarranted custody changes.’” Affirmed.