SEHLKE v. VANDERMAAS

Docket No. 262346.

707 N.W.2d 603 (2005)

268 Mich. App. 262

Matthew Lynn SEHLKE, Plaintiff-Appellee, v. Jennifer Lanae VANDERMAAS, Defendant-Appellant.

Court of Appeals of Michigan.

Decided September 27, 2005, at 9:00 a.m.

Released for Publication December 27, 2005.


Attorney(s) appearing for the Case

William G. Jackson, P.C. (by Roberta R. Ballard), St. Johns, for the plaintiff.

Willingham & Coté, P.C. (by Curtis R. Hadley and Robert B. Bellgowan, Jr.), East Lansing, for the defendant.

Before: SAWYER, P.J., and TALBOT and BORRELLO, JJ.


SAWYER, P.J.

We are asked in this case to revisit our holding in Dehring v. Dehring1 that an intrastate change of domicile does not constitute a sufficient change of circumstance to reopen a custody case. In light of statutory changes enacted after our decision in Dehring, we now hold that an intrastate change in legal residence in excess of 100 miles constitutes a change in circumstances sufficient to reopen a custody matter...

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