Divorce; Appellate jurisdiction; Final order; MCR 7.202(6); MCR 7.203(A)(1); Joint tax return; Collateral attack; Surman v Surman; Domestic relations attorney fees; MCR 3.206(D)(2)(b); Compensatory civil contempt; MCL 600.1721; Alpena Cnty Bd of Cnty Rd Comm’rs v Tadajewski
 

The court held that it lacked jurisdiction over defendant-wife’s appeal from a postjudgment divorce order requiring cooperation with filing a joint tax return and awarding attorney fees. The judgment of divorce required the parties to file a joint 2024 tax return, and the later order directed defendant to cooperate with the parties’ marital tax preparer and pay plaintiff $1,500 in attorney fees. The court first held that defendant could not challenge the joint-return requirement through an appeal from the October motion-to-compel order because the July judgment of divorce was the final order that included this requirement, and under Surman, a party “cannot wait until the entry of a subsequent final order to untimely appeal an earlier final order.” The court next held that it lacked jurisdiction over the tax-preparer directive because the October order did not dispose of all claims, did not involve custody, parenting time, or domicile, and any appeal from an attorney-fee order is “limited to the portion of the order” awarding fees. Finally, the court held that the attorney-fee award itself was not appealable of right because MCR 3.206(D)(2)(b), which applies when fees are incurred because a party “refused to comply with a previous court order,” implements the trial court’s contempt power. Relying on Tadajewski, the court concluded that such an award is “a form of compensatory civil contempt” under MCL 600.1721 and therefore “is not a final order appealable of right.” Dismissed for lack of jurisdiction.