The trial court erroneously referred this custody case to the Friend of the Court without first determining whether there was proper cause or a change in circumstances that necessitated a review of custody and parenting time, the Michigan Court of Appeals has ruled.

The trial court in this case wrongly imposed restrictions on a father’s parenting time of his three minor children, the Michigan Court of Appeals has ruled.

The plaintiff-mother was properly awarded sole custody of the parties’ child and the defendant-father was correctly ordered to continue supervised parenting time.

A trial court correctly denied a father’s request to 1) change the parenting time schedule and 2) remove a right-of-first-refusal provision from the parties’ divorce judgment.