ARTICLE 1.24.2020 CHILD CUSTODY PARENTING TIME MODIFICATION, (810 235-1970 Attorney Terry Bankert Custody; Parenting time; Lieberman v. Orr; Shade v. Wright; Rains v. Rains; MCL 722.27(1)(c); Established custodial environment (ECE); Vodvarka v. Grasmeyer; Proper cause or change in circumstances (COC) Source) e-journal #72081, Unpublished 1.2.2020 Michigan Court of Appeals No., 34556. AT THE MICHIGAN COURT OF APPEALS Father had argued that the trial court erred by finding that his request for additional parenting time would alter the children’s ECE and by holding that he failed to show a proper cause or CHANGE IN CIRCUMSTANCES(COC) to justify modification of the child custody determination. FATHER HAD ASKED FOR EQUAL PARENTING TIME ARGUING IT WOULD NOT ALTER THE CUSTODIAL ENVIRONMENT. THE COURT'S JOB IS TO ENSURE THE CHILD'S STABILITY. “The Child Custody Act authorizes a trial court to award custody and parenting time arising out of a child custody dispute and imposes a gatekeeping function on the trial court to ensure the child’s stability. . . .” Lieberman, 319 Mich App at 78, citing MCL 722.27. THE FARTHER FAILED HIS RESPONSIBILITY TO SHOW A CHANGE IN CIRCUMSTANCES. A trial court may modify or amend its previous judgments or orders, including those addressing custody or parenting time issues, “for proper cause shown or because of change of circumstances. . . .” MCL 722.27(1)(c). The standards for this threshold showing differ depending on whether the moving party seeks to change custody or to modify parenting time. Lieberman, 319 Mich App at 81. The controlling case Vodvarka addresses the requisite standards for showing proper cause or a change of circumstances relative to requests to modify child custody. When a proposed change of circumstances will affect a child’s established custodial environment, the applicable legal framework for analyzing the matter is that set forth in Vodvarka. [Id. (citations omitted).] In determining whether a proposed change to parenting time would alter an established custodial environment, an important consideration is to what extent the proposed change will decrease a parent’s time with the child. Lieberman, 319 https://www.instagram.com/p/B7tSmMgl_mT/?igshid=1nhhhvgbimjw2