Custody; Best-interest factors; MCL 722.23; Sabatine v Sabatine; Legal custody; Joint custody; Kuebler v Kuebler; Parenting time; Established custodial environment (ECE); MCL 722.27(1)(c); Domestic violence; Factor (j) (MCL 722.23(j))

The court held that the trial court did not abuse its discretion by granting defendant-father sole legal custody and continuing equal parenting time, despite one harmless error in weighing the best-interest factors. After remand, the trial court held a two-day trial at which both parties presented witnesses and exhibits concerning the child’s medical care, school services, autism-related needs, allegations of domestic violence, and the parties’ ability to coparent. On appeal, the court held that the trial court’s best-interest findings were not against the great weight of the evidence as to all but one of the disputed factors. The court found that factor (j) was “the most concerning factor” because plaintiff-mother did not support coparenting, wanted defendant to have the least possible time, and had a history of failing to share information, while defendant was more likely to keep plaintiff informed. The court also held that the record supported findings favoring defendant as to guidance, medical care, and the child’s home, school, and community record because the child showed stronger progress in defendant’s care and defendant became more engaged with services after explanations from providers. Although the trial court should have weighed factor (e) neutrally because it concerns family permanence rather than hostility between households, the error was harmless because four other factors favored defendant and none favored plaintiff. Affirmed.