Paternity action; Failure to include a notice of hearing with filed motions; MCR 2.119(C); Procedural due process; Claim that an individual cannot be held responsible for child support absent evidence of a promissory note or contract; The Paternity Act; MCL 722.717; Personal & subject-matter jurisdiction; MCL 600.701; MCL 722.714

The court found that defendant (who was proceeding in propria persona) abandoned all his arguments on appeal in this paternity action, and further concluded none of them had merit. The trial court did not err in failing to address his motions where they did not comply with the applicable court rules, his due process rights were not violated, and the trial court had both personal and subject-matter jurisdiction. Further, there “is no requirement in MCL 722.717 that the trial court require proof of a contract or promissory note in order to enter a paternity judgment and child support order.” Thus, the court affirmed the trial court’s judgment of paternity and uniform child support order setting defendant’s child support obligation. He did not “include a notice of hearing with any of the motions he filed in the trial court.” Without a notice of hearing, none of his motions were “filed in accordance with MCR 2.119 and were not properly scheduled to be heard by the trial court.” He failed to explain how the trial court’s failure to hear or respond to his motions violated his due process rights, and the court held that his “rights were not violated as he had notice of the hearing regarding the prosecutor’s motion for child support on [12/9/22], and the opportunity to be heard at the hearing.” He also appeared to contend “that without evidence of a promissory note or contract, he cannot be held responsible for child support.” However, pursuant to MCL 722.717, “the trial court had the authority to enter the judgment of paternity and uniform child support order.” It determined that he was the child’s father “and entered the paternity judgment after defendant was properly served with the summons and failed to file an answer.” As to personal jurisdiction over defendant, he “was domiciled in Michigan at the time he was served at his verified address in Muskegon, Michigan. As a result, the trial court had general personal jurisdiction over” him under MCL 600.701. It also had subject-matter jurisdiction under MCL 722.714 “to determine the paternity of a child born out of wedlock and to order child support.”