COA 371474 ALEXIS MARIA ALDRIDGE V TREVOR ERIC ALDRIDGE Opinion - Per Curiam - Unpublished 6/9/2026

371474Court Of AppealsJun 9, 2026

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If this opinion indicates that it is “FOR PUBLICATION,” it is subject to
revision until final publication in the Michigan Appeals Reports.
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S T A T E O F M I C H I G A N
C O U R T O F A P P E A L S
ALEXIS MARIA ALDRIDGE,
Plaintiff-Appellee,
UNPUBLISHED
June 09, 2026
10:17 AM
v No. 371474
Ionia Circuit Court
TREVOR ERIC ALDRIDGE, LC No. 2024-036403-DM
Defendant-Appellant.
Before: CAMERON, P.J., and BOONSTRA and SWARTZLE, JJ.
PER CURIAM.
Defendant appeals by leave granted1 the trial court’s order denying his motion to transfer
venue. The trial court entered a consent judgment of divorce while this appeal was pending. We
dismiss the appeal as moot.
I. PERTINENT FACTS AND PROCEDURAL HISTORY
Defendant and plaintiff married on July 11, 2020 and have three children together. They
lived in Newaygo County. The parties separated on February 26, 2024. Plaintiff moved to Ionia
County and filed for divorce there on April 24, 2024. Defendant filed a timely motion to transfer
venue to Newaygo County, where he continued to reside. The trial court denied the motion after
a hearing. Defendant sought leave to appeal, and this Court granted the application.
On April 9, 2025, the trial court entered a consent judgment of divorce that included the
following relevant provisions:
Pending Appeal. There is a pending appeal with the Court of Appeals
regarding venue. The parties stipulate that the entry of this Agreement shall not
defeat jurisdiction of the Court of Appeals nor render the pending appeal moot.
1 Aldridge v Aldridge, unpublished order of the Court of Appeals, entered February 14, 2025
(Docket No. 371474).

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This agreement shall be binding on the parties and if the appeal is successful in the
Defendant’s favor, this judgment of divorce shall act as a settlement agreement.
While the appeal is pending, this settlement agreement is enforceable by this Court.
* * *
Post-judgment enforcement. The parties will perform their respective
executory obligations with the utmost good faith. Either party may apply to this
court for enforcement of the provisions of this judgment. Enforcement proceedings
may be brought in Circuit Court or in District Court of Ionia, as applicable, subject
to the ruling of the Court of Appeals on the pending venue issue.
* * *
Retention of jurisdiction. The court specifically retains jurisdiction over
this case and the parties for the purpose of assuring compliance with the executory
provisions of this judgment and reserves the right to make such other and further
orders as necessary to implement them.
* * *
This judgment resolves the last pending claim and closes the case, except
for any matter over which this court retains continuing jurisdiction by law. This
provision is intended to comply with MCR 2.602(A)(3).
On May 13, 2026, we entered an order2 directing the parties to be prepared at oral argument to
address whether this appeal is moot and authorizing the parties to file supplemental briefs
addressing that issue. In response, plaintiff filed a supplemental brief contending that this appeal
is not moot. Defendant did not file a supplemental brief.
II. MOOTNESS
A. STANDARD OF REVIEW
“The applicability of a legal doctrine, such as mootness, is a question of law” that we
review de novo. TM v MZ, 501 Mich 312, 315; 916 NW2d 473 (2018). Questions of law involving
jurisdiction, venue, and the interpretation of contracts are also reviewed de novo. In re Contempt
of Pavlos-Hackney, 343 Mich App 642, 667; 997 NW2d 511 (2022); Reed v Reed, 265 Mich App
131, 141; 693 NW2d 825 (2005).
B. ANALYSIS
“Whether a case is moot is a threshold question that we address before reaching the
substantive issues of a case.” Gleason v Kincaid, 323 Mich App 308, 314; 917 NW2d 685 (2018).
2 Aldridge v Aldridge, unpublished order of the Court of Appeals, entered May 13, 2026 (Docket
No. 371474).

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A case is moot if “a subsequent event makes it impossible for this Court to grant relief” because
the case no longer “rest[s] upon existing facts or rights and presents nothing but abstract questions
of law.” Id. at 314-315. “Where a court’s adverse judgment may have collateral legal
consequences for a [party], the issue is not necessarily moot. When no such collateral legal
consequences exist, . . . the case is moot and should ordinarily be dismissed without reaching the
underlying merits.” In re Detmer/Beaudry, 321 Mich App 49, 56; 910 NW2d 318 (2017). But
even if a case is moot, this Court may reach the underlying merits if the issue “(1) is of public
significance, (2) is likely to recur, and (3) may evade judicial review.” Gleason, 323 Mich App
at 315. This Court has previously held that a venue issue in a divorce case was moot because the
parties had “already received their divorce.” Funk v Funk, unpublished per curiam opinion of the
Court of Appeals, issued April 2, 2015 (Docket No. 319467), p 1.3
In this case, the parties have “already received their divorce,” id., but the consent judgment
of divorce contains unique provisions purporting to preserve the venue issue for appellate review
and to condition the parties’ choice of venue for enforcement proceedings on the outcome of this
appeal. “Consent judgments of divorce are contracts and treated as such.” Andrusz v Andrusz,
320 Mich App 445, 452; 904 NW2d 636 (2017).
Despite the provisions of the consent judgment, we hold that this case is moot for three
reasons. First, we are not bound by the parties’ stipulation that the consent judgment does not
render this appeal moot. “It is well established that a court is not bound by the parties’ stipulations
of law.” In re Estate of Finlay, 430 Mich 590, 595; 424 NW2d 272 (1988). The issue of mootness
is a question of law that we determine without any deference to proceedings in the lower court.
Reed, 265 Mich App at 141. Even if the parties have agreed that the doctrine of mootness should
not apply, “[i]t is within the inherent power of a court, as the judicial body, to determine the
applicable law in each case.” In re Estate of Finlay, 430 Mich App at 595.
Second, rendering a decision on the venue issue would have no practical effect because the
case no longer rests upon existing facts or rights, now that the trial court has entered the consent
judgment of divorce. The provision stating that “[e]nforcement proceedings may be brought in
Circuit Court or in District Court of Ionia, as applicable, subject to the ruling of the Court of
Appeals on the pending venue issue,” creates only the illusion that our ruling on the issue would
have any legal consequence. See In re Detmer/Beaudry, 321 Mich App at 56. The parties agreed
to remain bound by the consent judgment as a settlement agreement even if defendant prevailed in
this appeal, so our decision would not affect the outcome of the divorce. And by agreeing to the
judgment, the parties also agreed that the trial court “specifically retains jurisdiction over this case
and the parties for the purpose of assuring compliance with the executory provisions of this
judgment and reserves the right to make such other and further orders as necessary to implement
them.” (Emphasis added). In other words, the parties effectively consented to the Ionia Circuit
3 Unpublished opinions are not binding on this Court, but they may be considered for their
instructive or persuasive value. Cox v Hartman, 322 Mich App 292, 307; 911 NW2d 219 (2017).

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Court’s authority over enforcement or other postjudgment proceedings regardless of what this
Court holds.4
Third, the venue issue now presents an abstract question of law. See Gleason, 323 Mich
App at 315. The issue on appeal would require this court to interpret MCL 600.1621 and
MCL 552.9(1) to determine whether the trial court clearly erred by denying defendant’s motion to
transfer venue, which he filed contemporaneously with his answer to the complaint. But given the
entry of the consent judgment of divorce, that issue is no longer of any moment as it relates to this
case. Moreover, after a trial court grants a judgment of divorce, a transfer of venue is governed
by MCR 3.212, which neither party has addressed on appeal. Defendant requests that we transfer
the case to Newaygo County, but we are not in a position to grant what is now effectively
postjudgment request to transfer venue without properly addressing the requirements for such
transfers under MCR 3.212.5 The procedural rights underlying a transfer of venue have changed,
rendering the issue on appeal nothing more than a thought experiment. Such abstract questions of
law are moot.
Furthermore, the limited exception to the doctrine of mootness does not apply because the
venue issue will not evade judicial review. See Gleason, 323 Mich App at 315. Either the trial
4 We note that the postjudgment-enforcement provision of the consent judgment is partially
unenforceable because it conflicts with the plain language of MCL 600.1021(1)(a), which states
that “the family division of circuit court has sole and exclusive jurisdiction” over divorce cases
that “commenced on or after January 1, 1998.” (Emphasis added). Therefore, enforcement
proceedings could not be brought in the District Court of Ionia because district courts lack
jurisdiction over divorce cases. A contractual provision is unenforceable if it conflicts with the
plain language of a statute or otherwise violates the law or public policy. Smitham v State Farm
Fire & Cas Co, 297 Mich App 537, 549-550; 824 NW2d 601 (2012).
5 Under MCR 3.212(B)(1), a party’s postjudgment motion to transfer venue may be granted only
if all four of these conditions are met:
(a) the transfer of the action is requested on the basis of the residence and
convenience of the parties, or other good cause consistent with the best interests of
the child;
(b) neither party nor the court-ordered custodian has resided in the county
of current jurisdiction for at least 6 months prior to the filing of the motion;
(c) at least one party or the court-ordered custodian has resided in the
county to which the transfer is requested for at least 6 months prior to the filing of
the motion; and
(d) the county to which the transfer is requested is not contiguous to the
county of the current jurisdiction.
Naturally, the trial court did not make these findings when it considered defendant’s
prejudgment motion to transfer venue.

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court or this Court may enter an order staying trial-court proceedings pending the outcome of an
appeal. MCR 7.209. Rather than moving to stay the proceedings in this case, the parties rendered
this appeal moot by consenting to a judgment of divorce that effectively resolved the venue issue.
A similarly situated party who is successful in staying proceedings or willing to proceed through
trial could bring the same issue to us in the future.
For these reasons, we dismiss this appeal as moot.
/s/ Thomas C. Cameron
/s/ Mark T. Boonstra
/s/ Brock A. Swartzle

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