Motion to terminate an ex parte personal protection order (PPO); MCL 600.2950(1)(l); Burden of proof; MCL 600.2950(4); Failure to brief the issues presented

Holding that the trial court did not abuse its discretion in denying respondent’s motion to terminate the PPO, the court affirmed. Petitioner obtained the ex parte PPO after an altercation at her home with respondent on Thanksgiving. They share a young child. On appeal, the court first noted that respondent cited no legal authority for the requested relief and provided “no analysis applying the facts of the case to the applicable law. Instead, his brief on appeal contains only a series of conclusory statements taking the form of a one-page ‘Statement of Facts’ and a one-page ‘Statement of Questions.’” On this basis alone, it “would affirm the trial court’s order.” It further found that there was no merit in any of his arguments. While he asserted that petitioner’s evidence did not meet the burden of proof, the court disagreed. She “provided a transcript of an audio recording of respondent at the time of the altercation, the contents of which were authenticated by respondent, which included,” among other things, his threats that she “would get her ‘head cracked’ and that he would ‘hurt and destroy’ her. Those threats were made after respondent let himself into petitioner’s home uninvited, refused to give her back the key he used to gain entry, and while” he was verbally abusing her “and openly carrying a firearm. At a minimum, that evidence constituted reasonable cause regarding petitioner’s apprehension of violence, i.e., reasonable cause to believe that respondent would be violent towards [her] consistent with MCL 600.2950(1)(l).” The court also found no error in the trial court’s rejection of irrelevant evidence proffered by respondent.