Domestic PPO standard; MCL 600.2950(1) & (4); Ex parte PPO; MCL 600.2950(12); “Reasonable cause” requirement; SP v BEK; “Positive finding” of prohibited behavior; Kampf v Kampf

The court held that the trial court did not abuse its discretion by denying petitioner’s request for a domestic PPO and did not err by denying an ex parte PPO because petitioner failed to show “reasonable cause” that respondent “may commit” an act listed in MCL 600.2950(1) and failed to show “immediate and irreparable injury” under MCL 600.2950(12). After petitioner filed for divorce, she sought an ex parte PPO alleging years of emotional abuse, a March 2024 incident involving respondent allegedly bruising his son’s face, alleged “hacking into accounts,” an August 2024 appearance at her father’s home, and recent online harassment of her employer. The trial court denied ex parte relief, then held a hearing and found petitioner credible regarding emotional abuse and PTSD but concluded “there’s not enough evidence here for the personal protection order,” emphasizing petitioner had no direct contact with respondent since August 2024 and lacked proof tying respondent to the alleged Facebook harassment because “anyone can create a Facebook page.” On appeal, the court rejected petitioner’s claim that venue drove the denial, explaining the trial court merely asked why the PPO was filed in a different county than the divorce case and suggested that a mutual no-contact order might be available in the divorce case, not that venue was improper. The court further held credibility findings about emotional abuse did not compel a PPO because the petitioner still had to establish conduct within the statute, and “the court must make a positive finding of prohibited behavior by the respondent before issuing a PPO.” Turning to ex parte relief, the court held petitioner’s allegations were largely “too stale” to show immediate harm, noting the last direct contact was over four months before filing and the Secretary of State address-change allegation did not show irreparable injury. It also held petitioner’s claim that respondent was “always prepared” to shoot another person was not tied to specific, imminent conduct toward petitioner. Affirmed.