The Michigan COA ruled, in this custody case, the trial court correctly invalidated the "domicile provision" in the parties' consent judgment of divorce and found that the best interests of the children must be considered before letting the defendant move out-of-state.

The trial court’s decision to suspend Mother’s parenting time had the effect of modifying the award of joint physical custody in the consent judgment of divorce, and MCR 3.207 did not apply to the case.

An attorney fee award in this divorce action must be vacated, the Michigan Court of Appeals has ruled, because the trial court did not make a finding as to whether the requested fee was reasonable.

Even though the parties’ consent judgment of divorce included an offset provision, the defendant’s challenge to enforcing that provision is an improper collateral attack.

The plaintiff’s appeal is limited to that portion of the trial court’s order denying her request for attorney fees as a sanction, the Michigan Court of Appeals has ruled.

The trial court correctly modified the parties’ custody order to give the mother sole legal and physical custody of the children.

A consent JOD under which the parties agreed that the defendant would pay the plaintiff one-half of his military retirement benefits is preempted by federal law and is unenforceable.