In Corporan v. Henton, the defendant father appealed the trial court‟s order denying him an evidentiary hearing on his motion for a change of custody. He argued that he had presented sufficient evidence to warrant a hearing. The Michigan Court of Appeals (1) held the trial court “employed the proper procedure by first determining whether proper cause or change of circumstances had been established by a preponderance of the evidence”; and (2) affirmed “the trial court‟s ruling that negative financial changes . . . are more appropriately addressed in achild support context rather than in a change of custody motion.” The father had alleged financial difficulties, (specifically that the mother failed to pay her rent timely, a fact relevant under best interests factors). However, the court found this did not meet the Vodvarka standard because the mother‟s financial difficulties, if any, could be remedied by an increase in child support. The father further alleged that the minor child‟s grades had significantly declined but the trial court held that this “did not demonstrate a change of circumstances,” and the court found that although “the child‟s grades have declined to a minor extent in certain subjects, the child‟s grades do not show anything, more than the normal life changes (both good and bad) that occur during the life of a child.‟” Read More …