in Re Jcb, 971 N.W.2d 705

Petitioner obtained a nondomestic ex parte personal protection order (PPO) on July 11, 2017, based on repeated harassment, insults, and threats by his neighbor (respondent); the PPO was in effect until July 17, 2019.
Respondent was served with the PPO on July 18, 2017, moved to terminate it on August 14, 2017, and the trial court denied that motion after a hearing on September 6, 2017.
On September 23, 2018, petitioner alleges respondent approached him while he was mowing a neighbor’s lawn, punched and scratched him, and ripped his shirt; petitioner called police and filed a motion to show cause for PPO violation.
After hearings, the trial court found respondent guilty of criminal contempt for violating the PPO beyond a reasonable doubt, based largely on petitioner’s credible testimony and recognition of respondent and his vehicle.
At sentencing respondent received three days’ jail, a $200 fine, and $600 in costs/attorney fees; respondent appealed, arguing (1) the PPO was invalid and improperly left in place, (2) insufficient evidence supported contempt, (3) inadequate findings, and (4) cumulative error.

Issue	Petitioner’s Argument	Respondent’s Argument	Held
Timeliness/validity of PPO challenge	PPO was valid and respondent’s collateral attack is untimely	The ex parte PPO was invalid and should have been terminated; trial court erred in denying termination	Denial of motion to terminate was appealable 21 days after Sept. 6, 2017; respondent missed that deadline, so challenge to PPO validity is foreclosed
Sufficiency of evidence for criminal contempt	Petitioner argues the assault violated express PPO terms (approach/confront) and prior findings supporting the order may be considered	Respondent contends petitioner had to reprove a course of conduct/stalking beyond the single incident and evidence was insufficient	Sufficient evidence existed; petitioner need not reprove entire stalking pattern at contempt hearing and a single prohibited confrontation/assault violated the PPO; conviction affirmed
Adequacy of trial-court findings	Petitioner: court’s oral findings showed awareness of issues and applied the law	Respondent: findings were insufficient under MCR 3.708(H)(4)	Finding and conclusions on record were adequate; further detail not required because appellate review was possible
Cumulative error / due process	No prejudicial errors impacted verdict	Multiple errors deprived respondent of fair process	No cumulative errors shown; due process claim fails

Hayford v Hayford, 279 Mich App 324 (trial court abuse-of-discretion standard for PPOs)
United States v. Rylander, 460 U.S. 752 (contempt proceeding does not permit relitigation of the underlying order)
In re Contempt of Auto Club Ins. Ass’n, 243 Mich App 697 (standard of review for contempt orders)
In re Contempt of Henry, 282 Mich App 656 (bench-trial sufficiency review in contempt matters)
In re Kabanuk, 295 Mich App 252 (factfinding review; affirm if competent evidence supports findings)
People v Nowack, 462 Mich 392 (circumstantial evidence and reasonable inferences can support conviction)
People v Lockett, 295 Mich App 165 (limits on addressing hypothetical constitutional infirmities on appeal)
People v Cole, 491 Mich 324 (interpretation/application of court rules reviewed de novo)
Triple E Produce Corp v Mastronardi Produce, Ltd, 209 Mich App 165 (MCR 2.517 satisfied where court aware of issues and applied law)
People v Dobek, 274 Mich App 58 (cumulative-error standard)