Brittney Golden v. Hashim Ward, 357875

Plaintiff Brittney Golden filed paternity complaints in May 2019; defendant Hashim Ward acknowledged paternity of three children but sought joint custody and support under the Michigan Child Support Formula (MCSF).
A referee entered an interim order granting plaintiff sole physical custody and joint legal custody; defendant was ordered to pay modest interim support and was given parenting time.
After a three-day evidentiary hearing (Jan–Mar 2021), the trial court awarded plaintiff sole custody, finding multiple best-interest factors (including domestic violence, stability, provision of material needs, and the children’s school record) weighed for plaintiff; the court credited plaintiff and found defendant not credible.
The court found the parties unable to cooperate for joint custody because of defendant’s conduct (alleged physical and verbal abuse, undermining plaintiff, removing a child out of state, turning off court-ordered communication, and noncompliance with orders).
For child support the court estimated defendant’s 2020 income at $60,000 (listing $19,488 unemployment and $40,000 from “Home Rehabilitation”), ordered $1,896 monthly support, but made no explanation for the $40,000 figure.
The Court of Appeals affirmed the sole-custody award but remanded the child-support calculation for further factual findings and, if imputing income, explicit consideration of MCSF imputation factors.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Custody: whether sole custody to plaintiff was erroneous	Golden: sole custody supported by best-interest factors and parties’ inability to cooperate	Ward: trial court erred in awarding sole custody (argues findings for some best-interest factors were wrong)	Affirmed — trial court’s findings re best-interest factors (c, d, h, k) not against great weight; no abuse of discretion; parties cannot cooperate, so sole custody appropriate (Fisher)
Child support: whether trial court properly calculated and justified defendant’s income/support	Golden: court properly estimated income based on evidence presented	Ward: court erred in estimating income and awarding support without adequate factual findings or explanation	Remanded — trial court failed to explain $40,000 “Home Rehabilitation” figure; must revisit support calculation, make findings on income sources, and, if imputing income, expressly apply MCSF imputation factors (2021 MCSF 2.01(G)(2))

Lieberman v. Orr, 319 Mich App 68 (2017) (appellate standards for custody review)
Fisher v. Fisher, 118 Mich App 227 (1982) (joint custody requires parental ability to cooperate; sole custody appropriate if parents cannot agree)
Shulick v. Richards, 273 Mich App 320 (2006) (trial court must consider Child Custody Act best-interest factors)
Berger v. Berger, 277 Mich App 700 (2008) (appellate deference to trial-court credibility determinations)
Rains v. Rains, 301 Mich App 313 (2013) (definition of abuse of discretion in custody context)
Sinicropi v. Mazurek, 273 Mich App 149 (2006) (trial court may weigh custody factors differently as appropriate)
Stallworth v. Stallworth, 275 Mich App 282 (2007) (trial court must follow MCSF or explain deviations)
Peterson v. Peterson, 272 Mich App 511 (2006) (standards of review for child-support calculations)
Carlson v. Carlson, 293 Mich App 203 (2011) (clear-error standard for factual findings underlying child support)
Blazer Foods, Inc. v. Restaurant Props., Inc., 259 Mich App 241 (2003) (issues raised for first time in reply brief may be forfeited)