Devlin Schmidt v. Ashley Ugolini

CourtMichigan Court of Appeals
DecidedJune 27, 2024
Docket368319
StatusUnpublished

This text of Devlin Schmidt v. Ashley Ugolini (Devlin Schmidt v. Ashley Ugolini) 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
Devlin Schmidt v. Ashley Ugolini, (Mich. Ct. App. 2024).

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

DEVLIN SCHMIDT, UNPUBLISHED June 27, 2024 Plaintiff-Appellee,

v No. 368319 Bay Circuit Court ASHLEY UGOLINI, Family Division LC No. 19-007472-DM Defendant-Appellant.

Before: O’BRIEN, P.J., and M. J. KELLY and FEENEY, JJ.

PER CURIAM.

Defendant appeals by leave granted1 the trial court’s order granting plaintiff’s motion to change parenting time and school for the parties’ child, LMS. Defendant argues that the trial court wrongly concluded that the change to defendant’s parenting time would not modify LMS’s established custodial environment with defendant, and consequently applied the wrong standard of proof to its best-interest determination. Defendant further argues that three of the trial court’s findings for the best-interest factors were against the great weight of the evidence or involved clear legal error. We agree with defendant that the trial court applied the wrong standard of proof to its best-interest determination, and that the court legally erred in its assessment of one of the best- interest factors. We accordingly vacate the trial court’s order and remand for further proceedings.

I. BACKGROUND

The parties divorced in September 2020 and shared joint legal and joint physical custody of LMS. Their consent judgment of divorce gave the parties equal parenting time with LMS through a week on/week off schedule. Following the divorce, plaintiff continued living in the marital home in Bay City, while defendant moved to Livonia. LMS attended preschool during both parents’ parenting time, attending a different school depending on which parent she was with.

1 Schmidt v Ugolini, unpublished order of the Court of Appeals, entered February 13, 2024 (Docket No. 368319).

-1- When it came time for LMS to enroll in kindergarten, this arrangement could no longer work, and the parties needed to decide on a single school for LMS to attend. After the parties were unable to agree where LMS would attend kindergarten, plaintiff filed a motion in January 2023 requesting that LMS attend Bay City Public Schools and that defendant’s parenting time be modified accordingly. Defendant opposed the motion and requested that LMS attend Plymouth- Canton Public Schools.

The trial court referred the motion to the Friend of the Court (FOC). The FOC recommended that LMS be enrolled in Bay City Public Schools and that defendant’s parenting time be limited to primarily weekends and the summer months.

Defendant objected to the FOC’s recommendation, and the trial court held an evidentiary hearing. Following that hearing, the trial court granted plaintiff’s motion and adopted the FOC’s recommendation. In its order, the trial court recognized that the parties shared joint custody of LMS and that LMS had an established custodial environment with both parents, but said, “Regardless of the school chosen by the Court, the established custodial environment would not be altered, that remains with both parents.” Based on this finding, the court applied a preponderance-of-the-evidence standard to its best-interest determination. Addressing the best- interest factors, the court said that it only needed to “consider the best-interest factors relevant to the issue” of school enrollment, and accordingly limited its best-interest analysis to factors (a), (b), (d), (e), (g), (h), and (j). The court found that factors (d), (e), and (j) favored plaintiff and that the other applicable factors favored neither party. Based on its review of the best-interest factors, the court found by a preponderance of the evidence that enrolling LMS in Bay City Public Schools was in her best interests. The court adopted the parenting-time schedule recommended by the FOC.

This appeal followed.

II. STANDARD OF REVIEW

MCL 722.28 provides that when reviewing a lower court order in a custody dispute, “all orders and judgments of the circuit court shall be affirmed on appeal unless the trial judge made findings of fact against the great weight of evidence or committed a palpable abuse of discretion or a clear legal error on a major issue.” This statute distinguishes among three types of rulings “and assigns standards of review to each.” Dailey v Kloenhamer, 291 Mich App 660, 664; 811 NW2d 501 (2011) (quotation marks and citation omitted). The first type is factual findings, which “are reviewed under the ‘great weight of the evidence’ standard.” Id. “A finding of fact is against the great weight of the evidence if the evidence clearly preponderates in the opposite direction.” Pennington v Pennington, 329 Mich App 562, 570; 944 NW2d 131 (2019). The second type is questions of law, which are reviewed for clear legal error. Id. “A trial court commits clear legal error when it incorrectly chooses, interprets, or applies the law.” Id. (quotation marks and citation omitted). The third type is discretionary rulings, which are reviewed for a palpable abuse of discretion. Dailey, 291 Mich App at 664. “An abuse of discretion exists when the trial court’s decision is palpably and grossly violative of fact and logic.” Id. at 664-665 (quotation marks, citations, and alteration omitted).

-2- III. ESTABLISHED CUSTODIAL ENVIRONMENT

On appeal, defendant first argues that the trial court erred when it found that granting plaintiff’s request to enroll LMS in Bay City Public Schools and adjust defendant’s parenting time would not alter LMS’s established custodial environment with defendant, which led the court to apply the wrong standard to its best-interest determination.

In circumstances analogous to this case, our Supreme Court in Pierron v Pierron, 486 Mich 81, 85-86; 782 NW2d 480 (2010), explained how analyzing a request to change a child’s school can vary depending on how the change will affect the child’s established custodial environment:

The Child Custody Act “applies to all circuit court child custody disputes and actions, whether original or incidental to other actions.” MCL 722.26(1). The act provides that when parents share joint legal custody—as the parties do here— “the parents shall share decision-making authority as to the important decisions affecting the welfare of the child.” MCL 722.26a(7)(b). However, when the parents cannot agree on an important decision, such as a change of the child’s school, the court is responsible for resolving the issue in the best interests of the child. Lombardo v Lombardo, 202 Mich App 151, 159; 507 NW2d 788 (1993); see also MCL 722.25(1). When resolving important decisions that affect the welfare of the child, the court must first consider whether the proposed change would modify the established custodial environment. The established custodial environment is the environment in which “over an appreciable time the child naturally looks to the custodian in that environment for guidance, discipline, the necessities of life, and parental comfort.” MCL 722.27(1)(c). While an important decision affecting the welfare of the child may well require adjustments in the parenting time schedules, this does not necessarily mean that the established custodial environment will have been modified. Brown v Loveman, 260 Mich App 576, 595-596; 680 NW2d 432 (2004). If the required parenting time adjustments will not change whom the child naturally looks to for guidance, discipline, the necessities of life, and parental comfort, then the established custodial environment will not have changed. See id. The court may not “ ‘change the established custodial environment of a child unless there is presented clear and convincing evidence that it is in the best interest of the child.’ ” Id. at 585, quoting MCL 722.27(1)(c). [Footnotes omitted.]

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Related

Pierron v. Pierron
782 N.W.2d 480 (Michigan Supreme Court, 2010)
Reed v. Reed
693 N.W.2d 825 (Michigan Court of Appeals, 2005)
Brown v. Loveman
680 N.W.2d 432 (Michigan Court of Appeals, 2004)
Powery v. Wells
752 N.W.2d 47 (Michigan Court of Appeals, 2008)
Foskett v. Foskett
634 N.W.2d 363 (Michigan Court of Appeals, 2001)
Lombardo v. Lombardo
507 N.W.2d 788 (Michigan Court of Appeals, 1993)
Demski v. Petlick
873 N.W.2d 596 (Michigan Court of Appeals, 2015)
Jason Andrew Griffin v. Rebekah Marie Griffin
916 N.W.2d 292 (Michigan Court of Appeals, 2018)
Kimberly Marie Marik v. Peter Brian Marik
925 N.W.2d 885 (Michigan Court of Appeals, 2018)
Dailey v. Kloenhamer
811 N.W.2d 501 (Michigan Court of Appeals, 2011)
Rains v. Rains
836 N.W.2d 709 (Michigan Court of Appeals, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Devlin Schmidt v. Ashley Ugolini, Counsel Stack Legal Research, https://law.counselstack.com/opinion/devlin-schmidt-v-ashley-ugolini-michctapp-2024.