Child custody; Change of a child’s residence more than 100 miles from the child’s legal residence; Change-of-residence factors; MCL 722.31(4); Distinguishing Brausch v Brausch; Motion to modify custody; Proper cause or a change of circumstances; MCL 722.27(1)(c); Lieberman v Orr; The statutory best-interest factors; MCL 722.23; Great weight of the evidence

The court held that there was “no basis for reversal” in this case involving the parties’ child custody arrangement. The trial court modified the arrangement so that the children would attend school where plaintiff-father lives and not where defendant-mother lives. On appeal, the court rejected defendant’s arguments that the trial court: (1) improperly analyzed some of the change-of-residence factors, (2) “improperly looked to circumstances that occurred after the original custody and parenting-time order, but before the modification to the order that preceded the order on appeal, in concluding that the existing” arrangement should be revisited, and (3) made findings under the statutory best-interest factors that were against the great weight of the evidence. First, “MCL 722.31 was inapplicable to plaintiff’s motion because, despite the manner in which it was titled, plaintiff sought to modify custody without also seeking to change the children’s residences.” Next, given “defendant’s own pleadings, the trial court did not err in holding that the custody arrangement should be revisited because there was evidence that adequately supported proper cause or a change in circumstances.” Finally, the trial court’s findings as to the best-interest factors were not against the great weight of the evidence, and defendant’s arguments regarding its findings were “not persuasive.” Affirmed.