A trial court’s postjudgment order awarding attorney fees under MCR 3.206 for the defendant’s alleged noncompliance with an order in her divorce case “constitutes a form of compensatory civil contempt” and “is not a final order appealable of right,” the Michigan Court of Appeals has ruled, dismissing the defendant’s appeal.

Previously, the Court of Appeals found plain error after the Trial Court held that Respondent-Mother was not entitled to reasonable efforts to reunify her with her children and when it failed to inform Respondent-Mother of her right to appeal the Trial Court’s removal of the children from her care.

Hockett, a published and binding opinion from Oct. 2021, concerns whether a trial court had sufficient statutory grounds to exercise jurisdiction over a minor child who has mental health issues.

The MI SCT is set to hear oral arguments on the application to appeal the decision in In re Holbrook, Minor, a case involving statutory grounds for a trial court to take jurisdiction over a minor.