PPO case; MCL 600.2950(30)(d); Issuance of an ex parte PPO; MCR 3.310(B)(5); Pickering v Pickering; Acts necessitating a PPO; MCL 600.2950(1); Whether there was imminent danger; Kampf v Kampf; Motion to modify or rescind a PPO; MCL 600.2950(13); Mootness; In re Tchakarova; People v Richmond

The court dismissed as moot petitioner’s appeal of the trial court’s order granting respondent’s motion to terminate an ex parte PPO. On 1/19/21, petitioner filed a petition for a PPO against respondent, who was her husband and with whom she shared children, alleging she feared for her safety because of his threatening and violent behavior. On the same day, the trial court entered an order prohibiting respondent from having contact with petitioner in the manner she requested. The order provided it would remain in effect until 1/18/22. In response, respondent filed a motion to terminate or modify the PPO. At the hearing, the trial court found that petitioner no longer wanted to have a relationship with respondent, and that he “‘has not favorably reacted to that, basically, engaging in conduct that can only be described . . . as stalking.’” It indicated it would only terminate the PPO after the parties presented documentation of the initiation of divorce proceedings. On 3/23/21, after divorce proceedings had been initiated, it granted his motion to terminate the PPO. On appeal, petitioner argued that the trial court made an error of law by terminating the PPO upon the initiation of divorce proceedings, or, alternatively, that it abused its discretion because there was reasonable cause to believe respondent might commit one or more acts listed in MCL 600.2950(1). The court held that because the PPO had already expired, it could not afford her any relief, and the appeal was moot.