A custody order does not determine a child’s domicile for purposes of the no-fault act. As the domicile rule set forth in Grange Ins Co of Mich v Lawrence, 494 Mich 475 (2013) requires courts to treat child custody orders as dispositive of the question of domicile, Grange is overruled.

The January 2013 issue of the Michigan Family Law Journal includes an article by attorneys Scott Bassett and Carmen Moyer in their column "Unpublished decision of the month." The column addressed the family law decision in Rosema v Rosema.