The trial court properly declined to enforce a California custody determination because the California court did not have subject matter jurisdiction.

An Ecuadorian mother’s taking of her minor child from MI to Ecuador without notifying the father, did not preclude the possibility that the child had become a “habitual resident”.

The Michigan trial court dismissed the custody case in Michigan, finding that under the UCCJEA jurisdiction was proper in Georgia because the Georgia case had been filed first.

The Michigan Court of Appeals has peremptorily vacated a trial court order that denied a mother’s motion to transfer a child-custody case from Michigan to Idaho.