JESSICA RAE BROWN V DUSTIN HAMER

Court of Appeals, State of Michigan
ORDER
JESSICA RAE BROWN V DUSTIN HAMER
Docket No. 379727
LC No. 15-006954-DS
Stephen L. Borrello
Presiding Judge
Michael J. Riordan
Daniel S. Korobkin
Judges
The motion for immediate consideration is GRANTED.
Pursuant to MCR 7.211(C)(4) and MCR 7.205(E)(2), and in lieu of granting the application
for leave to appeal, we PEREMPTORILY REVERSE the March 2, 2026 order of the trial court to the
extent that the court attempted to retain jurisdiction over a portion of this child custody proceeding and to
the extent that the court modified an existing parenting time order in a matter over which it determined it
no longer possessed exclusive, continuing jurisdiction. After the court determined that it no longer had
exclusive, continuing jurisdiction and after the court determined that it should transfer this matter to
another state, see MCL 722.1202; MCL 722.1207, the court could not exercise jurisdiction over a part of
this case. The court’s bifurcation of the proceedings in this manner was not authorized by the Uniform
Child-Custody Jurisdiction and Enforcement Act (UCCJEA), and it was contrary to the UCCJEA’s goal
of preventing the entry of conflicting orders or proceedings in custody matters. See White v Harrison-
White, 280 Mich App 383, 388; 760 NW2d 691 (2008). Moreover, defendant’s voluntary participation in
mediation did not waive jurisdiction, in whole or in part, over the enforcement of the order that resulted
from mediation. See Foster v Wolkowitz, 486 Mich 356, 367; 785 NW2d 59 (2010). On remand, the
court shall transfer the entirety of this matter to South Carolina.
_______________________________
Presiding Judge

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