Ariana Rosalie Omaits V Ryan Andrew Zerbe

CourtMichigan Court of Appeals
DecidedMarch 10, 2022
Docket20220310
StatusUnpublished

This text of Ariana Rosalie Omaits V Ryan Andrew Zerbe (Ariana Rosalie Omaits V Ryan Andrew Zerbe) is published on Counsel Stack Legal Research, covering Michigan Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ariana Rosalie Omaits V Ryan Andrew Zerbe, (Mich. Ct. App. 2022).

Opinion

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports.

STATE OF MICHIGAN

COURT OF APPEALS

ARIANA ROSALIE OMAITS, UNPUBLISHED March 10, 2022 Petitioner-Appellee,

v No. 357995 Genesee Circuit Court RYAN ANDREW ZERBE, Family Division LC No. 13-906558-DP Respondent-Appellant.

Before: REDFORD, P.J., and SAWYER and MURRAY, JJ.

PER CURIAM.

Respondent, Ryan Andrew Zerbe, appeals by right the trial court’s order granting the motion of petitioner, Ariana Rosalie Omaits, under the Uniform Child-Custody Jurisdiction and Enforcement Act (UCCJEA), MCL 722.1101 et seq., and transferring jurisdiction of the custody case regarding the parties’ child to the state of Georgia. We affirm.

I. FACTUAL BACKGROUND

The initial custody order in this case involved a 2013 paternity complaint. Respondent last saw the child in September 2016 and was incarcerated in November 2016. In January 2017, petitioner and the child moved to Georgia. In March 2021, respondent was released on parole. Petitioner filed a case in Georgia seeking child support, and respondent sought in Michigan to change the child’s custody. Petitioner moved to dismiss the Michigan case for lack of jurisdiction, asserting that Georgia had exclusive jurisdiction under the UCCJEA.

The trial court ultimately determined that, while it had exclusive, continuing jurisdiction over the child because it had issued the initial custody order, it was appropriate to no longer exercise exclusive jurisdiction because neither the child nor petitioner lived in Michigan and the child no longer had significant connections with Michigan. In the alternative, the court held that Michigan was not a convenient forum. The court transferred the child’s case to Georgia.

-1- II. STANDARDS OF REVIEW

This Court reviews de novo questions of law concerning whether the trial court has jurisdiction under UCCJEA. Cheeseman v Williams, 311 Mich App 147, 150; 874 NW2d 385 (2015). This Court reviews the trial court’s decision regarding whether to exercise jurisdiction under the UCCJEA for an abuse of discretion. Id. The court has not abused its discretion if its decision is within the range of principled outcomes. Id. Generally, this Court reviews a court’s factual findings in a custody case to determine whether those findings were against the great weight of the evidence. Foskett v Foskett, 247 Mich App 1, 5; 634 NW2d 363 (2001). A finding is against the great weight of the evidence when the evidence clearly preponderates against it. Id.

III. ANALYSIS

MCL 722.1202(1) provides that the trial court that has previously made a custody decision may no longer have exclusive, continuing jurisdiction under certain circumstances:

Except as otherwise provided in [MCL 722.12041], a court of this state that has made a child-custody determination consistent with [MCL 722.1201 or MCL 722.1203] has exclusive, continuing jurisdiction over the child-custody determination until either of the following occurs:

(a) A court of this state determines that neither the child, nor the child and 1 parent, nor the child and a person acting as a parent have a significant connection with this state and that substantial evidence is no longer available in this state concerning the child’s care, protection, training, and personal relationships.

(b) A court of this state or a court of another state determines that neither the child, nor a parent of the child, nor a person acting as the child’s parent presently resides in this state.

(2) A court of this state that has exclusive, continuing jurisdiction under this section may decline to exercise its jurisdiction if the court determines that it is an inconvenient forum under [MCL 722.1207].

As an initial matter, respondent argues that the trial court erred by deciding this issue without a hearing. We conclude that the trial court was not required to hold an evidentiary hearing to decide this preliminary legal issue.

The trial court must conduct an evidentiary hearing before modifying a child’s custody, even on a temporary basis. Grew v Knox, 265 Mich App 333, 336; 694 NW2d 772 (2005). However, the trial court need not hold an evidentiary hearing before deciding a threshold legal issue, even if that issue is fact-intensive. Corporan v Henton, 282 Mich App 599, 605; 766 NW2d 903 (2009). In this case, the trial court’s decision regarding whether to exercise continuing

1 MCL 722.1204 concerns temporary emergency jurisdiction.

-2- exclusive jurisdiction was a threshold legal issue, and we conclude that it was not required to hold an evidentiary hearing before deciding petitioner’s motion.

Next, respondent argues that the trial court erred by failing to find that Michigan was the child’s home state because she lived in Michigan for six months before the initial action was filed and because the Georgia court did not have jurisdiction when petitioner filed her case in Georgia. “It is settled that error requiring reversal may only be predicated on the trial court’s actions . . . .” See Lewis v LeGrow, 258 Mich App 175, 210; 670 NW2d 675 (2003). In this case, respondent’s argument that Michigan maintained jurisdiction is correct, but the trial court did not find to the contrary. The court did not err.

Respondent argues that, because he still resides in Michigan, the trial court could not have determined that it no longer had exclusive jurisdiction over the case. Respondent’s argument lacks merit because it addresses MCL 722.1202(1)(b), which is separate from the subdivision on which the trial court relied. It is not disputed that respondent continues to reside in Michigan, which would be sufficient for the trial court to exercise continuing jurisdiction under MCL 722.1202(1)(b). However, MCL 722.1202 contains two alternative subdivisions under which the court may decline to exercise continuing jurisdiction. The trial court relied on MCL 722.1202(1)(a), under which the court may decline to exercise exclusive, continuing jurisdiction if it finds that neither the child, nor the child and one parent, nor the child and one person acting as a parent have a significant connection with Michigan and substantial evidence is no longer available in Michigan concerning the child’s care, protection, training, and personal relationships. Consistent with this subdivision, the court determined that petitioner and the child no longer had a connection to Michigan, and that substantial evidence was no longer available in Michigan concerning the child’s care, protection, and relationships. The trial court did not err by applying one of the two alternative bases from which it could determine that it no longer had exclusive, continuing jurisdiction.

Next, respondent argues that the trial court erred by finding that the child no longer had a significant connection with Michigan. We conclude that the court’s finding was not against the great weight of the evidence.

A parent’s continued presence in Michigan is relevant to whether a child has a significant connection with Michigan. Guardalupe Hernandez v Mayoral-Martinez, 329 Mich App 206, 212; 942 NW2d 80 (2019). However, evidence of the child’s current care and well-being, as well as evidence that the child speaks with the parent and the parent’s financial support of the child, are relevant to the determination whether there is a significant connection between the child and the parent. See id. at 213. Additional evidence regarding the parents’ fitness and ability to care for the child are part of the evidence that would allow the court to determine a child’s custody. Id.

Considering respondent’s admissions in this case, we are not convinced that its outcome fell outside the range of reasonable outcomes.

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Related

Terrien v. Zwit
648 N.W.2d 602 (Michigan Supreme Court, 2002)
Lewis v. LeGrow
670 N.W.2d 675 (Michigan Court of Appeals, 2003)
Corporan v. Henton
766 N.W.2d 903 (Michigan Court of Appeals, 2009)
Petraszewsky v. Keeth
506 N.W.2d 890 (Michigan Court of Appeals, 1993)
Foskett v. Foskett
634 N.W.2d 363 (Michigan Court of Appeals, 2001)
Cheesman v. Williams
874 N.W.2d 385 (Michigan Court of Appeals, 2015)
Grew v. Knox
694 N.W.2d 772 (Michigan Court of Appeals, 2005)

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Bluebook (online)
Ariana Rosalie Omaits V Ryan Andrew Zerbe, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ariana-rosalie-omaits-v-ryan-andrew-zerbe-michctapp-2022.