Motion to modify custody & parenting time; Subject-matter jurisdiction; The Uniform Child-Custody Jurisdiction & Enforcement Act (UCCJEA); MCL 722.1202(1)

The court affirmed the trial court’s 7/2/25 order denying plaintiff-mother’s (Dean) motion to modify custody of the child (BD). Dean first argued “that the trial court lacked jurisdiction to enter its custody and parenting-time orders because, as a result of her move to Georgia with BD, that state had exclusive jurisdiction under the” UCCJEA. The court noted that the “trial court maintained exclusive jurisdiction under MCL 722.1202(1) because no Michigan court determined that BD and” defendant-father (Hunter) “did not maintain a significant connection to Michigan.” Further, because “the trial court had exclusive, continuing jurisdiction over the case under MCL 722.1202(1), the [trial] court did not err by exercising jurisdiction over this dispute.” Next, the court found that to the extent Dean challenged the 7/2/25 order, her argument lacked merit. Although the trial “court did not explicitly state that Dean had failed to establish proper cause or a change of circumstances to modify custody, the” trial court’s statements indicated that it concluded as such. The trial “court also informed Dean that she could file objections to the FOC’s recommended order, and when Dean stated that she had already done so, [it] asked Dean if she wanted to proceed with the de novo hearing on her objections that day rather than returning to court the following week. Dean responded affirmatively.” The trial “court directed Dean to file the transcript of the [6/3/25] hearing and stated that it would review the matter.” Under the circumstances, the court could not “conclude that the trial court erred by denying Dean’s motion to modify custody.”