Child custody; Proper cause or a change of circumstances (COC); MCL 722.27(1)(c); Vodvarka v Grasmeyer; Established custodial environment (ECE); Bofysil v Bofysil; The child’s best interests; Lieberman v Orr; The statutory best-interest factors; MCL 722.23; Factors (b), (d), (e), (f), (j), & (l); Great weight of the evidence

Holding that the trial court did not err by awarding primary physical custody of the parties’ child to defendant-father, the court affirmed. The trial court initially awarded plaintiff-mother sole physical custody, both parties joint legal custody, and parenting time as they agreed. Defendant moved to Georgia, then plaintiff and the child moved to Illinois without the trial court’s permission and against defendant’s wishes. As such, defendant sought, and the trial court entered, an order for specified parenting time. Defendant later moved back to Michigan, and plaintiff moved back thereafter. Defendant eventually sought joint legal custody and primary physical custody or, in the alternative, increased parenting time. A referee found he made a prima facie showing of proper cause or COC for his custody motion to proceed. The trial court subsequently found that although an ECE existed with plaintiff, defendant proved by clear and convincing evidence that it was in the child’s best interests to change custody and awarded him primary physical custody. On appeal, the court first found that the trial court “did find that proper cause or a [COC] existed before addressing the merits of the motion.” It then rejected plaintiff’s argument that the trial court erred by finding that some of the best-interest factors slightly favored or favored defendant, noting the trial court’s “best-interest findings for the specific best-interest factors were overall not against the great weight of the evidence.” The trial court “cannot be said to have committed a palpable abuse of direction in weighing the best-interest factors and concluding that the ‘sum total’ of the best-interest factors warranted a change in custody.” Contrary to plaintiff’s argument, “there is no presumption that the trial court gave equal weight to all the factors.” In addition, a trial court “is under no obligation to expressly state the relative weight, if any, placed on the best-interest factors.” Considering that the trial court found “none of the factors individually favored plaintiff, and we have upheld [its] findings on all but that under factor (f) (and on that, plaintiff admits it’s only equal), the trial court did not abuse its discretion by determining that defendant established by clear and convincing evidence that it was in the child’s best interests to change custody.”