Consider Patton v Patton, an Oakland County case, unpublished. The opinion was released yesterday, March 18, 2014. Defendant Father appealed the trial court's modification of 50/50 joint custody. After trial, Plaintiff Mother was awarded sole legal and sole physical custody of the parties' 16-year-old minor child.
1) The trial court, after one day of trial, appointed a legal as GAL. The issues on appeal were whether she was a GAL or an LGAL and the scope of her appointment.
2) Challenges to the trial court's analysis of the best interest factors. One addressed the conclusion that Mother prevailed on the factor of "moral fitness." Since lack of moral fitness is often raised today in scorched earth family law litigation, to the benefit of no one, usually, it's a good idea to take a look at this again. In Patton, the COA stated: