Domicile change; MCL 722.31(4)(a); Rains v Rains; Great weight of the evidence; Parenting time preservation; MCL 722.31(4)(c); Mogle v Scriver; Domestic violence; MCL 722.31(4)(e); Vodvarka v Grasmeyer; Evidence; Motion in limine; Judicial disqualification; MCR 2.003(C); Cain v Michigan Dep’t of Corrs

The court held that the trial court properly denied plaintiff-mother’s motion to move the children’s domicile from Michigan to Texas because she did not prove that the statutory relocation factors supported the move. Plaintiff, who had primary physical custody, sought to relocate the parties’ two children to Houston after receiving a job offer there. She asserted that the move would improve her finances, provide better schools and services, and give her a stronger support network. The trial court denied the motion after hearing testimony about the Texas job, the parties’ parenting-time history, and plaintiff’s proposed relocation plan. It later denied reconsideration. On appeal, the court held that the trial court’s findings under MCL 722.31(4)(a) were not against the great weight of the evidence because, while the job would improve plaintiff’s quality of life, she did not present evidence showing that the move had the capacity to improve the children’s quality of life. The court noted that plaintiff did not identify what needed services the children lacked, offered only limited proof of better schooling, and did not substantiate the claimed Houston support system. The court next held that MCL 722.31(4)(c) did not favor relocation because the trial court reasonably doubted plaintiff’s future compliance with a long-distance parenting-time plan in light of her earlier “reluctant” compliance and prior contempt. The court also held that plaintiff did not show error in the trial court’s treatment of domestic violence under MCL 722.31(4)(e), or the denial without prejudice of her motion in limine. Finally, it rejected her judicial-bias claim, explaining that adverse rulings and clerical misattributions did not overcome the strong presumption of impartiality. Affirmed.