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 2-1 published decision in Bensch upholds the rule first set forth in People v Peterson, 62 Mich App 258 (1975), allowing criminal defendants to reject probation for jail time.