Child custody; Established custodial environment (ECE); Proper cause or change of circumstances; The statutory best-interest factors; MCL 722.23; Factors (c), (d), (e), (f), (h), & (j)

The court held that the trial court did not make findings against the great weight of the evidence in concluding that best-interest factors (c), (d), (e), (f), (h), and (j) all favored defendant-mother, and thus, “did not palpably abuse its discretion by awarding [her] sole physical custody”​ of the parties’ children. The trial court granted the parties’ joint legal custody over the children, with defendant receiving sole physical custody and plaintiff-father receiving parenting time. On appeal, the court rejected plaintiff’s argument that the trial court erred by incorrectly finding various best-interest factors in favor of defendant, particularly when the children had an ECE with plaintiff in Michigan, not with defendant in Colorado. It found that the trial court’s decision to slightly favor defendant on factor (c) was not against the great weight of the evidence, and that its decision to favor her on factors (d), (e), (f), (j), and (h) were also not against the great weight of the evidence. Affirmed.