Child custody; Proper cause or change of circumstances; Best interests; MCL 722.23; Established custodial environment (ECE); Clear & convincing evidence; Legal custody; Physical custody; School district; MCL 722.26a; Friend of the Court (FOC) report; MCL 552.505(1)(g); Domestic violence; Court-order violations

The court held that the trial court did not err by awarding defendant-father primary physical and sole legal custody of the parties’ children and changing their school district. Plaintiff-mother argued the trial court improperly revisited custody, but the court held that proper cause existed because the mother unilaterally enrolled the children in a different school district without the father’s consent, which “unquestionably had the potential to significantly affect the children’s well-being.” The court did not need to decide whether her repeated contact with a romantic partner, despite a no-contact order, also established proper cause. The court next rejected the mother’s challenge to the FOC report because the trial court did not admit it as an exhibit, used it only for “background and context,” and made independent findings on the best-interest factors. As to those factors, the court held that the trial court’s findings were not against the great weight of the evidence. The record supported findings that the mother “blatantly violated” court orders, minimized domestic violence involving her romantic partner, moved the children out of their school district without a clear reason, caused a burdensome commute, and contributed to instability in the children’s home and school lives. The father’s home, by contrast, was stable, routine-based, and permanent. The court concluded “the trial court centered the children’s interests” rather than punishing the mother for violating orders. Affirmed.