Petition for a nondomestic PPO; MCL 600.2950a(1); MCL 750.411h, i, & s; “Stalking”; MCL 750.411h(1)(d); Hayford v Hayford; “Course of conduct”; MCL 750.411h(1)(a); “Harassment”; MCL 750.411h(1)(c); “Unconsented contact”; MCL 750.411h(1)(e); “Emotional distress”; MCL 750.411h(1)(b); MCR 3.703(G); Whether a trial court complies with MCL 600.2950a’s requirements when denying a petition for an ex parte PPO in a nondomestic relationship by merely concluding the allegations are “insufficient” for ex parte relief; Requirement that a trial court state its reasons for denying a PPO in writing; MCL 600.2950a(7); MCR 3.705(A)(5); In re JCB; Harmless error

The court held that the trial court failed to comply with MCL 600.2950a when it denied petitioner’s petition for an ex parte PPO by merely finding the allegations were “insufficient” for such relief. Further, because it “failed to state the specific reasons to either refuse or issue the PPO,” the court was unable to determine whether the trial court properly exercised its discretion in denying the petition. Thus, it vacated the order and remanded to the trial court “to state in writing the specific reasons for denying, or in the alternative, granting the petition.” According to the petition, petitioner agreed to foster a dog (Joy) from an organization over which respondent had some level of control or ownership. Petitioner alleged that during the time that followed, respondent grew “‘enraged’” about various issues, and began harassing her verbally and by showing up at her house, taking pictures, and at one point throwing eggs at the house. “Ultimately, petitioner alleged respondent’s conduct caused her to suffer from anxiety for which her doctor was treating her with medication.” In a one-page order, the trial court denied her petition without a hearing stating only: “Insufficient allegations for ex parte relief.” The court found the trial court’s “conclusory determination that the allegations [we]re ‘insufficient’ for ex parte relief” was inadequate for appellate review. “The trial court did not hold a hearing on petitioner’s request for nondomestic PPO and issued an order denying the request for relief because the allegations were ‘insufficient’ because they did not ‘meet the statutory threshold or requirements.’ Without any findings of fact or any conclusions of law based on those facts from the trial court, we are unable to discern which threshold or requirement petitioner failed to satisfy. The statute requires the trial court to state the ‘specific reasons’ for denying the petition, . . . and an explanation more detailed than simply ‘insufficient’ is needed to satisfy the statute and aid appellate review.” The court noted that petitioner “alleged, and supported with documentary evidence, that she was subjected to multiple instances of unconsented contact . . . .” These allegations “were coupled with allegations and evidence of threats made by respondent that she would take Joy away from [her] and that she would ‘ruin’ and ‘destroy’” her.