Whether due process was denied by limiting cross-examination in PPO-termination proceedings; HMM v JS; JLS v HRS; Whether the firearm possession prohibition was an abuse of discretion; MCL 600.2950a(26)

The court affirmed denial of respondent’s motion to modify/terminate a PPO, holding there was no due-process violation and that inclusion of a firearm prohibition was within the trial court’s discretion. Petitioner alleged months of unsolicited texts, emails, letters, and social-media messages, sometimes from new numbers after blocking old ones. At the hearing, the trial court swore in both parties, reviewed the submitted messages, and repeatedly invited respondent to present witnesses or evidence. Respondent admitted sending the communications but said she wanted petitioner to know about an affair with petitioner’s spouse. Unlike HMM, where the trial court halted cross-examination, respondent here neither requested to cross-examine nor identified foreclosed inquiries, and the trial court afforded her an opportunity to respond to the evidence. As such, there was no error that affected substantial rights. As to firearms, MCL 600.2950a(26) expressly authorizes prohibiting purchase or possession in a PPO. Given the volume and persistence of communications that caused petitioner fear, the trial court’s refusal to carve out a firearms exception for respondent’s employment or hunting was not outside the range of principled outcomes. The PPO prohibiting stalking and firearm possession remained in place.