Criminal contempt of court for violation of a nondomestic personal protection order (PPO) issued under MCL 600.2950a; MCL 600.2950a(23); MCR 3.708(B)(1) & (H)(3); In re JCB; Stalking; MCL 750.411h & i; Sufficiency of the evidence; Principle that a respondent cannot relitigate the validity of the PPO in a challenge to the criminal contempt; In re JCB; Findings of fact; MCR 3.708(H)(4); MCR 2.517; Cumulative effect

The court held that the trial court did not err by holding respondent in criminal contempt of court for violating a nondomestic PPO issued under MCL 600.2950a, or by sentencing him to 93 days in jail. Petitioner filed her petition for the PPO against respondent, her neighbor, alleging he “threatened her life on multiple occasions, pulled a knife on her and her husband, walked past her house yelling obscenities, told her four-year-old daughter that petitioner was a ‘bitch,’ and told her daughters that he would kill their mother.” The trial court issued the PPO, prohibiting respondent from “engaging in stalking activities under MCL 750.411h and MCL 750.411i.” He was specifically enjoined from “following petitioner, appearing within sight of petitioner, appearing at petitioner’s workplace or residence, approaching or confronting petitioner in a public place or on private property, and entering onto petitioner’s property.” Respondent moved to terminate the PPO, claiming it contained “fabricated accusations” against him. The trial court denied his motion. The PPO was extended twice, and respondent was held in criminal contempt for violating the PPO three separate times. He was sentenced to 45 days in jail for the second violation, and then another term of 93 days in jail for the third violation, to be served concurrently with the sentence he was already serving. On appeal, the court rejected his argument that there was insufficient evidence to establish beyond a reasonable doubt that he violated the PPO. The PPO “prohibited respondent from ‘following or appearing within sight of the petitioner’ and from ‘approaching or confronting the petitioner in a public place or on private property.’ There was an abundance of evidence proving beyond a reasonable doubt that [he] violated these two specific prohibitions.” The court also rejected his claim that the trial court failed to make specific findings of fact and law, and instead simply made an inadequate generalized statement that he violated the PPO. “The findings, both factual and legal, revealed that the trial court was aware of the issues and correctly applied the law. Further explanation by the trial court is not necessary to facilitate appellate review.” Finally, it rejected his contention that the cumulative effect of the errors deprived him of his federal and state constitutional due-process rights. “Because there were no errors, there can be no cumulative effect of errors requiring reversal.” Affirmed.