Nondomestic ex parte PPO; Appeals in PPO cases; MCR 3.709; Timing; MCR 7.204(A)(1); Criminal contempt for failing to comply with a PPO; MCL 600.2950a(23); Burden of proof; MCR 3.708(H)(3); Sufficiency of the evidence to support a criminal contempt; Principle that a contempt proceeding does not open to reconsideration the legal or factual basis of the order; United States v Rylander; Requirements for an ex parte PPO; MCL 600.2950a(12); “Stalking”; MCL 750.411h(1)(d) & i; “Course of conduct”; MCL 750.411h(1)(a); PF v JF; “Harassment”; MCL 750.411h(1)(c); “Emotional distress”; MCL 750.411h(1)(b); “Unconsented contact”; MCL 750.411h(1)(e); Findings of fact & conclusions; MCR 3.705(A)(2); MCR 3.708(H)(4); MCR 2.517; Cumulative error

The court held that respondent’s challenge to the validity of the PPO underlying his criminal contempt was foreclosed. In addition, the evidence was sufficient to show that he violated the PPO and was properly found in criminal contempt. Further, the trial court did not err in providing its findings of fact and law. Finally, respondent was not entitled to relief based on cumulative error. The trial court found respondent in criminal contempt for violating a PPO by punching petitioner (his neighbor) as petitioner was cutting another neighbor’s lawn. It sentenced him to 3 days in jail and ordered him to pay $200 in fines and $600 in court costs and attorney fees. On appeal, the court rejected his argument that the trial court erred by denying his motion to terminate the nondomestic ex parte PPO because it was invalid, finding appellate relief was precluded as he failed to timely challenge this issue. “[T]he time for filing respondent’s claim of appeal commenced” in 9/17, and he “had 21 days after the denial of the motion to terminate to file his claim of appeal as of right.” However, he did not file his appeal until 7/19, after the finding of criminal contempt. The court also rejected his claim that there was insufficient evidence to support his criminal contempt conviction because the evidence did not establish a violation of the PPO. “Evidence was presented that petitioner was harassed and attacked by respondent, and the trial court found this evidence to be credible. The conduct occurred despite the trial court order precluding its occurrence.” The court next rejected his contention that the trial court provided insufficient findings of fact and law, requiring reversal of his conviction, noting the trial court “was aware of the issues, correctly applied the terms of the PPO to the facts, and found respondent in criminal contempt” for violating the PPO, and that “remand for further explanation would not aid” appellate review. Finally, the court rejected his argument that the cumulative effect of several errors deprived him of due process. “Because no errors have been identified, respondent is not entitled to appellate relief.” Affirmed.