In denying a divorced mother’s request for a change of domicile for herself and the parties’ children, the trial court made a “procedural misstep” by not properly addressing the 100-mile rule.

The Michigan COA ruled, in this custody case, the trial court correctly invalidated the "domicile provision" in the parties' consent judgment of divorce and found that the best interests of the children must be considered before letting the defendant move out-of-state.