Court of Appeal issues published domicile decision in Kessler v Kessler

From Kessler v Kessler,  295 Mich App 54 (2011), the Court held that the lower court was not obligated to consider the change of domicile factors, MCL 722.31, when the domicile change was requested as part of the original custody order.  Moreover, the trial court still has to determine the established custodial environment, even though it was making the original custody decision and even though the parties still lived together in the same house.

Both these decisions make sense in the context of established custody law.