Tamera L Laskaris v. Gus a Laskaris, 360963

Tamera and Guy Laskaris divorced in 2011; consent judgment required Guy to pay child support, spousal support, and college costs; four children with varying ages.
By 2017 Guy had over $200,000 in arrears; parties executed a stipulation and order (Sept. 20, 2017) reducing monthly child support, making child support non‑modifiable through April 20, 2031, and agreeing to share college costs.
The 2017 stipulation held existing arrears in abeyance so long as Guy stayed current and required Guy to pay "all reasonable attorney fees" if Tamera had to enforce the order.
In August 2021 Tamera moved to enforce the 2017 stipulation; Guy admitted arrears, sought modification, and argued the stipulation was unenforceable because it made child support non‑modifiable.
The trial court (March 2022) enforced the 2017 stipulated order, found no fraud/mistake/illegality, and awarded Tamera $7,413 in attorneys’ fees; Guy appealed.

Issue	Plaintiff's Argument (Tamera)	Defendant's Argument (Guy)	Held
Whether this Court has jurisdiction to review Guy’s collateral attack on the 2017 stipulation	Appeal as of right is limited to the postjudgment attorneys’ fee award; collateral attack is outside scope	The 2017 stipulation is unenforceable (non‑modifiable child support), so enforcement and fee provisions should be invalidated	Appeal of right under MCR 7.202(6)(a)(iv) is limited to the attorneys’ fee portion; collateral challenge to the stipulation is beyond this Court’s jurisdiction and, alternatively, waived
Whether Guy preserved/validly challenged the attorneys’ fee award and amount	Fee award is improper because it rests on an unenforceable stipulation	The parties agreed Guy would pay reasonable fees if enforcement was required; Guy did not object to amount or seek hearing	Guy waived and abandoned any challenge to the fee award by not objecting below, not requesting hearing, and not briefing fee‑reasonableness on appeal; fee award affirmed

Pioneer State Mutual Ins Co v Michalek, 330 Mich. App. 138 (2019) (appeals under MCR 7.202(6)(a)(iv) limited to attorney‑fee portion)
Chapdelaine v Sochocki, 247 Mich. App. 167 (2001) (a party cannot stipulate to an order and later attack it on appeal)
Farm Credit Servs of Mich’s Heartland, PCA v Weldon, 232 Mich. App. 662 (1998) (error cannot be assigned where aggrieved party contributed by plan or negligence)
Spires v Bergman, 276 Mich. App. 432 (2007) (stipulated orders are construed as contracts)
Mossing v Demlow Products, Inc, 287 Mich. App. 87 (2010) (appeal under MCR 7.202(6)(a)(iv) limited to fee award portion)
Jawad A Shah, MD, PC v State Farm Mut Auto Ins Co, 324 Mich. App. 182 (2018) (issues not raised below are forfeited on appeal)
MOSES, Inc v SEMCOG, 270 Mich. App. 401 (2006) (failure to adequately brief or support a claim constitutes abandonment)
Chen v Wayne State Univ, 284 Mich. App. 172 (2009) (jurisdictional issues reviewed de novo)