Divorce; Reasonableness of attorney fees; MCR 3.206(D)

After remand to the trial court for an evidentiary hearing to determine the reasonableness of the requested attorney fees, and what amount, if any, plaintiff-ex-wife was entitled to, the court found no errors warranting reversal and affirmed the trial court’s grant of her request for attorney fees after the hearing. The court concluded that the “trial court’s reasonableness determination was supported by plaintiff’s testimony at the evidentiary hearing. [She] testified that after the consent judgment was entered, she had to engage counsel due to defendant’s noncompliance with court-ordered weekly payments in” 5/19. Defendant-ex-husband “also violated other provisions of the judgment by failing to pay property taxes and credit card expenses, and failing to turn over to plaintiff the deed to a Jamaica property and the titles and possession of snowmobiles. This noncompliance resulted in plaintiff filing several motions to enforce the judgment from” 5/19 to 12/21. “Plaintiff acknowledged that the parties attended mediation sessions and entered into several stipulations related to defendant’s fulfilment of his obligations, but the parties ultimately failed to secure defendant’s compliance absent court intervention. Based on this testimony, the trial court properly concluded that an award of attorney fees under MCR 3.206(D)(2)(b) was reasonable based on defendant’s repeated noncompliance with the consent judgment.” In addition, it “properly considered the language of the consent judgment of divorce and limited plaintiff’s attorney-fee award to include only postjudgment fees related to enforcement of the judgment.” The consent judgment was entered on 9/21/18, “and the trial court properly limited the attorney-fee award to services rendered by plaintiff’s attorneys from” 5/22/19 to 12/22/21.