Thanks to Sheldon Larky, terrific family lawyer in Bingham Farms, Michigan for his contribution to our State Bar of Michigan Family Law Listserv this past week. What a lot of mentoring occurs on that listserv! In response to another lawyer's query, Shel wrote:
Pertinent to the appeal in the newly published Michigan case Eickelberg v Eickelberg, __ Mich App __ (2015): Under the 100 mile rule limitation in determining a child’s change of residence [MCL 722.31], the 100 mile rule means radial miles rather than road miles. Road miles refers to the distance between two points along the shortest route of public travel, while radial miles refers to the distance between two points as measured along a straight line. Bowers v Vandermeulen-Bowers, 278 Mich App 287; 750 NW2d 597 (2008), lv app den 481 Mich 908 (2008); Lash v Traverse City, 479 Mich 180, 183 n 1; 735 NW2d 628 (2007).