Lawrence L Simmons v. Office of Child Support Central Operations, 329955

In 1990 the trial court entered a filiation order finding Simmons the father of a child born in 1987 and ordering $20/week support until the child turned 18.
On March 18, 2015, the Office of Child Support Central Operations (OCS) sent a notice freezing $1,850.90 in Simmons’s credit union account as part of enforcement for unpaid support (MiCSES showed $17,480.38 arrears).
Simmons requested administrative review claiming he did not own the funds; OCS denied the review for lack of supporting documentation.
Simmons appealed to the trial court; OCS submitted MiCSES screenshots as record evidence and the trial court found the administrative record sufficient and denied Simmons’s motions for reversal.
The trial court affirmed OCS’s lien, concluding the support order remained valid for unpaid arrears incurred before the child turned 18; Simmons appealed to this Court of Appeals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether OCS’s lien was authorized despite the child turning 18 in 2005	Simmons: support obligation terminated at child’s 18th birthday; no post-2005 liability	OCS: arrears accrued before 18 remain enforceable; lien properly issued within statutory period	Court: Lien authorized; enforcement within statute of limitations
Whether statute of limitations barred enforcement	Simmons: payments ceased 2005 so enforcement period expired	OCS: MCL 600.5809(4) gives 10 years from last payment due (child’s 18th birthday) to enforce arrears	Court: SOL ran Nov 13, 2005–Nov 13, 2015; lien (Mar 18, 2015) was timely
Sufficiency of administrative record and use of MiCSES screenshots	Simmons: demanded certified record and challenged identity/ownership of funds	OCS: MiCSES records establish valid order and arrears; Simmons provided no supporting proof of mistake	Court: Trial court properly found MiCSES evidence adequate and denied motion to compel certified copy
Request for appellate damages as vexatious appeal	Simmons: N/A (plaintiff)	OCS: sought $600 for attorney time under MCR 7.216(C)	Court: Request procedurally improper (not filed as required motion); request rejected

Vanzandt v State Employees Retirement System, 266 Mich App 579 (discussing appellate standard for review of administrative decisions)
Rzadkowolski v Pefley, 237 Mich App 405 (ten-year enforcement period after child turns eighteen under MCL 600.5809(4))
Fette v Peters Const Co, 310 Mich App 535 (procedural requirement that requests for damages under MCR 7.216(C) must be made by motion)