In Song v Moore, an Oakland County case, the COA held that the trial court properly denied Respondent's Motion to Terminate or Modify a Personal Protection Order that limited him to supervised parenting time only with his adolescent son.
In Song, the mother testified that not only was she knocked around and bruised by the father, but that the father had pushed his son into a wall. Her petition did not, however, request supervised parenting time with the child.
Citing Brandt v Brandt, 250 Mich App 68, 70-72 (2002), the COA approved the Song trial court's order that limited the father to supervised parenting time and denied any modification of that order. In Brandt, a panel of the COA had held that a trial court could restrict the respondent’s conduct with his children, even though the petitioner had not alleged that the respondent was ever violent towards his children under MCL 600.2950(1)(j), the “ ‘catchall’ provision” of the PPO statute.
For greater insight into Song and Brandt, you can read those cases here:
Song: Download Song_v_Moore
Brandt: Download Brandt_v._Brandt
Note: Kudos to Vincent Giovanni, for the result in Song. Kudos to the following for the Brandt successful appeal: Family Law Project (by A. Michelle Lane, Delphia Simpson, and Rebecca E. Shiemke), and Michigan Poverty Law Program (by Lynelle Detzler Morgan), Ann Arbor, Ann Arbor, for Lisa M. Brandt.