Motion to terminate a personal protection order (PPO); Non-final order; MCR 7.202(6)(a)(i); MCR 2.604(A); Subject matter jurisdiction to grant a PPO; MCL 600.1021(1)(k); MCL 600.2950a(1); Reassignment of a pending case; MCL 600.1011; Reassignment of judges; MCR 8.111(C)(2); Motion for reconsideration; MCR 2.119(F)(3); Sanders v. McLaren-Macomb; Oral argument; MCR 2.119(F)(2)

The court held that the trial court’s 2015 order denying petitioner’s request for an ex parte PPO was not a final order that closed the case. Also, the trial court did not lack subject matter jurisdiction to grant the PPO. Finally, respondent was not entitled to oral argument on her motion for reconsideration, and nothing in the record suggested that the trial court abused its discretion in failing to permit it. The appeal arose from a non-domestic PPO. Respondent appealed the trial court’s denial of her motion to terminate the PPO. She contended that the trial court’s 2015 order denying petitioner’s request for an ex parte “PPO was a final order that closed the case, and that as a result all orders issued thereafter by the trial court in this case were void.” The 2015 order denied petitioner’s request that a PPO be issued against respondent on an ex parte “basis, finding that the facts alleged did not indicate that ‘immediate, irreparable harm will occur during the time required to give notice.’” It did not dispose of petitioner’s claim for a PPO, and the trial court later issued one. Respondent asserted on appeal that the trial court’s 2015 order indicated “final disposition closed,” and thus closed the case. However, nothing in the order indicated “that it was a final order disposing of the case.” Respondent appeared to base her claim that the order was “a final one upon the trial court’s Register of Actions, the first page of which includes an entry for the [2015] order labeled ‘final disposition closed.’ But despite the nomenclature employed in the trial court’s record-keeping system, the [2015] order did not dispose of all the claims nor did it adjudicate all the rights and liabilities of the parties, and therefore was not a final order.” The court also rejected as without merit respondent’s argument that the trial court lacked subject matter jurisdiction to issue the PPO “because the trial judge continued to preside over the case after her transfer to the civil and criminal division of the circuit court . . . .” Affirmed.