Divorce; Custody; Children’s best interests; MCL 722.23; Factors (d), (f), (i), (j), & (k); Demski v Petlick; Fletcher v Fletcher; In camera interview; Supervised parenting time; MCL 722.27a(1) & (7)(a)-(i); Property division; Sparks v Sparks; Categorization of property as marital or separate; Cunningham v Cunningham; Equitable distribution

The court held that the trial court did not err in (1) determining that it was in the children’s best interests for plaintiff-mother to have sole legal and physical custody of the parties’ children or (2) awarding defendant-father supervised parenting time. But it reversed the award to plaintiff of the entire value of two properties and remanded for the trial court to make findings on their value, “and on the extent of any distribution of those properties and associated debt.” As to custody, defendant challenged the trial court’s findings on best-interest factors (d), (f), (i), (j), and (k). The court concluded that because “the trial court did not explicitly address ‘the desirability of maintaining the continuity of those environments,’ with plaintiff, it erred in finding that factor (d) favored” her. But it did not err in finding that factor (f) favored plaintiff. Further, from “the brief findings placed on the record, some of which supported plaintiff’s position as to defendant’s poor relationship with the children,” the court could not “conclude that the trial court’s findings in favor of plaintiff on factor (i) were against the great weight of the evidence.” It also found no merit in “defendant’s argument that the in camera interview violated his due-process” rights. And it found that the trial court’s conclusion that factors (j) and (k) weighed in plaintiff’s favor was not against the great weight of the evidence. As to the property division, the court noted that the Detroit “house was purchased during the marriage,” the parties lived there together “during the marriage, and defendant testified that he extensively renovated it. Further, [he] continued to reside in the house when plaintiff left with the children, a period of approximately three years. The trial court failed to make findings on all the relevant factors, suggesting that awarding to plaintiff the house and any equity in it was inequitable, at least in the absence of an explanation why defendant’s renovations (if any) and contributions while living in the house during the entire marriage does not garner [him] any interest in” it. The record did not contain sufficient information to allow the court “(or the trial court) to determine whether the purported Jamaica property was marital or separate, its value, and whether the trial court’s distribution was equitable. Further, the trial court’s awarding of all assets to plaintiff and all debt to defendant” appeared inequitable. Affirmed in part, vacated in part, and remanded.