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Ireland v. Smith
Michigan Supreme Court
547 N.W.2d 686 (1996)
In 1991, Jennifer Ireland (plaintiff) and Steven Smith (defendant) had a daughter. Ireland and Smith were in high school at the time of their daughter’s birth. In 1993, Ireland petitioned for child support and custody. In 1994, the circuit court held a trial to determine custody. At the time of the trial, Ireland was attending a university and living with the daughter in the university’s family-housing unit. During the day, Ireland left the daughter at the university’s childcare center. Smith lived at home with his family. The circuit court concluded that it was in the daughter’s best interests to award Smith custody. The circuit court explained that it had applied the statutorily listed factors for the best-interests analysis and found that Ireland and Smith were even on all the factors except for one. This factor required considering the “permanence, as a family unit” of the potential custodial home. The circuit court found that the permanence factor favored Smith because he was living with his family and his mother could care for the daughter. The circuit court concluded that this was preferable to leaving the daughter at the university’s childcare center. Ireland appealed. The court of appeals remanded the case after finding that the circuit court had misapplied the facts by ignoring evidence that the daughter did well in the university’s childcare center and had misapplied the law by considering the acceptability of the daycare arrangements rather than the permanence of the family unit. The Michigan Supreme Court then reviewed the case.
Rule of Law
Holding and Reasoning (Per curiam)
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