Motion to terminate an ex parte personal protection order (PPO); Domestic PPOs; MCL 600.2950; Reasonable cause; Sufficiency of the trial court’s findings; MCR 2.613(A) & (C)

Holding that the trial court did not err in “finding reasonable cause to believe that respondent committed a prohibited act under MCL 600.2950(1)[,]” the court concluded he was not entitled to relief. He appealed the order denying his motion to terminate the ex parte PPO obtained by petitioner. The court noted that “the trial court was statutorily mandated to consider if [he] had previously committed a prohibited act,” and as a result, “the trial court did not err by finding that petitioner met her burden to continue the PPO because respondent ‘did commit,’ i.e., previously committed, a prohibited act. A series of incidents were alleged to have occurred between” 1/24 and 1/25 that the court determined “supported the trial court finding that reasonable cause existed to continue the ex parte PPO. There was reasonable cause to believe that respondent may commit an act listed in Subsection (1) because petitioner alleged and provided transcripts representing that respondent threatened several times to kill petitioner, [her] attorney, and their children. Given the allegations and documents attached to the petition, the trial court properly found reasonable cause to believe that respondent may commit one of the prohibited acts in MCL 600.2950(1), given that he previously did commit one of the prohibited acts.” As to his challenge to the sufficiency of the trial court’s findings, while it “could have made more explicit findings as to why continuation of the PPO was proven, a full review of the transcripts show that the trial court applied the correct standards and burdens but failed to expansively articulate its rationale on the record or in its written opinion.” The court found that, given the termination hearing testimony “and the trial court’s unique position to determine witness credibility and the weight given to evidence, [its] failure to state more complete reasoning on the record is not inconsistent with substantial justice.” Affirmed.