This Court gives deference to the trial court's factual judgments and special deference to the trial court's credibility assessments. [Brown v Brown, 332 Mich.App. 1, 8-9; 955 N.W.2d 515 (2020) (quotation marks and citations omitted).]
Pursuant to MCL 722.28, in a child-custody dispute, "all orders and judgments of the circuit court shall be affirmed on appeal unless the trial judge made findings of fact against the great weight of evidence or committed a palpable abuse of discretion or a clear legal error on a major issue." Brown v Brown, 332 Mich.App. 1, 8; 955 N.W.2d 515 (2020) (quotation marks and citation omitted).
"The plain language of MCL 722.23(d) includes the desirability of maintaining the existing environment within its scope." Brown v Brown, 332 Mich.App. 1, 20; 955 N.W.2d 515 (2020). According to defendant, the trial court improperly focused its analysis of Factor (d) on "speculative opinions about what might potentially happen in the future, rather than the consideration of LMS' past environments and the desire in maintaining those environments."
We affirm on appeal all orders and judgments of the circuit court pertaining to a child custody dispute "unless the trial judge made findings of fact against the great weight of evidence or committed a palpable abuse of discretion or a clear legal error on a major issue." MCL 722.28. See also Brown v Brown, 332 Mich.App. 1, 8; 955 N.W.2d 515 (2020).
Factor (c) "considers the capacity and disposition of the parties involved to provide the child with food, clothing, medical care or other remedial care recognized and permitted under the laws of this state in place of medical care, and other material needs." Brown v Brown, 332 Mich App 1, 19; 955 NW2d 515 (2020), quoting MCL 722.23(c) (quotation marks omitted). Regarding this factor, the trial court found that plaintiff served as the primary financial support for the family, both parties participated in CFM's medical care and felt capable meeting her medical needs, and both parties had a history of employment.
"Discretionary rulings, including a trial court's decision to change custody, are reviewed for an abuse of discretion." Brown v Brown, 332 Mich.App. 1, 8; 955 N.W.2d 515 (2020).
"In matters involving child custody, all orders and judgments of the circuit court shall be affirmed on appeal unless the trial judge made findings of fact against the great weight of evidence or committed a palpable abuse of discretion or a clear legal error on a major issue." Brown v Brown, 332 Mich.App. 1, 8; 955 N.W.2d 515 (2020)
The focus of factor (e) should be on the permanence of the family unit in each home. Brown v Brown, 332 Mich.App. 1, 21; 955 N.W.2d 515 (2020). KRM's relationship with family members who did not reside with either plaintiff or defendant is not relevant to this factor.
"This Court gives deference to the trial court's factual judgments and special deference to the trial court's credibility assessments." Brown v Brown, 332 Mich.App. 1, 9; 955 N.W.2d 515 (2020). "Questions of law are reviewed for clear legal error.
Court gives deference to the trial court's factual judgments and special deference to the trial court's credibility assessments. [Brown v Brown, 332 Mich.App. 1, 8-9; 955 N.W.2d 515 (2020) (quotation marks and citations omitted).]