Pro se post-divorce proceeding; Summary disposition; MCR 2.116(C)(8); Pleading requirements; MCR 2.111(A)(1) & 2.110(A)(1); Frivolous action sanctions; MCL 600.2591; MCR 2.625(A)(2); Signature certification; MCR 1.109(E); Judicial disqualification; MCR 2.003(D)(2)

The court held that plaintiff-ex-wife failed to state cognizable claims because her pleadings and appellate arguments were not “clear, concise, and direct,” and it upheld sanctions because the trial court did not err in finding the action “frivolous” and filed to “harass” defendant-ex-husband. Plaintiff filed a pro se civil action seeking divorce-related attorney fees, retroactive child support, unpaid rent, medical expenses, and other damages tied to domestic-assault allegations and later proceedings. Defendant moved for summary disposition and sanctions based on prior litigation and the incoherence and relitigation of claims. The court affirmed dismissal under MCR 2.116(C)(8) because MCR 2.111(A)(1) requires allegations to be “clear, concise, and direct,” and “even on appeal, it is unclear what plaintiff’s claims against defendant are.” The court deemed issues abandoned where plaintiff failed to provide authority or a developed argument. It also affirmed the attorney-fee sanction award, explaining MCL 600.2591 mandates fees when an action is “frivolous,” including when the primary purpose is to “harass, embarrass, or injure” or when the legal position is “devoid of arguable legal merit.” It held that the trial court did not err in concluding the filing violated MCR 1.109(E) because plaintiff’s signature certified the complaint was “well-grounded in fact” and “warranted by existing law,” which was not the case. The court declined to reach her request for judicial-disqualification relief because it affirmed and, in any event, plaintiff did not plead disqualification grounds “with particularity” or provide an adequate record. Affirmed.