Michigan Compiled Laws

Mich. Comp. Laws § 552.507 (2026)

Referee; designation by chief judge; powers; transcript of hearing; cost; de novo court hearing; request; interim order; review.

✓ current as of July 2026

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FRIEND OF THE COURT ACT

Act 294 of 1982

552.507 Referee; designation by chief judge; powers; transcript of hearing; cost; de novo court hearing; request; interim order; review.

Sec. 7.

(1) The chief judge may designate a referee as provided by the Michigan court rules.

(2) A referee may do all of the following:

(a) Hear all motions in a domestic relations matter, except motions pertaining to an increase or decrease in spouse support, referred to the referee by the court.

(b) Administer oaths, compel the attendance of witnesses and the production of documents, and examine witnesses and parties.

(c) Make a written, signed report to the court containing a summary of testimony given, a statement of findings, and a recommended order; or make a statement of findings on the record and submit a recommended order.

(d) Hold hearings as provided in the support and parenting time enforcement act, 1982 PA 295, MCL 552.601 to 552.650. The referee shall make a record of each hearing held.

(e) Accept a voluntary acknowledgment of support liability, and review and make a recommendation to the court concerning a stipulated agreement to pay support.

(f) Recommend a default order establishing, modifying, or enforcing a support obligation in a domestic relations matter.

(3) If ordered by the court, or if stipulated by the parties, a referee shall make a transcript, verified by oath, of each hearing held. The cost of preparing a transcript shall be apportioned equally between the parties, unless otherwise ordered by the court.

(4) The court shall hold a de novo hearing on any matter that has been the subject of a referee hearing, upon the written request of either party or upon motion of the court. The request of a party shall be made within 21 days after the recommendation of the referee is made available to that party.

(5) A hearing is de novo despite the court's imposition of reasonable restrictions and conditions to conserve the resources of the parties and the court if the following conditions are met:

(a) The parties have been given a full opportunity to present and preserve important evidence at the referee hearing.

(b) For findings of fact to which the parties have objected, the parties are afforded a new opportunity to offer the same evidence to the court as was presented to the referee and to supplement that evidence with evidence that could not have been presented to the referee.

(6) Subject to subsection (5), de novo hearings include, but are not limited to, the following:

(a) A new decision based entirely on the record of a previous hearing, including any memoranda, recommendations, or proposed orders by the referee.

(b) A new decision based only on evidence presented at the time of the de novo hearing.

(c) A new decision based in part on the record of a referee hearing supplemented by evidence that was not introduced at a previous hearing.

(7) Pending a de novo hearing, the referee's recommended order may be presented to the court for entry as an interim order as provided by the Michigan court rules. The interim order shall be served on the parties within 3 days and shall be subject to review as provided under this subsection.

History: 1982, Act 294, Eff. July 1, 1983 ;-- Am. 1985, Act 208, Eff. Mar. 1, 1986 ;-- Am. 1996, Act 144, Imd. Eff. Mar. 25, 1996 ;-- Am. 2004, Act 210, Eff. Oct. 1, 2004

PopularName Notes:

Friend of the Court

Notes of Decisions

Cited in 63 cases (27 in the last 5 years), 1986–2026 · leading case: Harvey v. Harvey, 668 N.W.2d 187 (Mich. Ct. App. 2003).

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Harvey v. Harvey, 668 N.W.2d 187 (Mich. Ct. App. 2003). · cites it 20× “§ 552.507(1), the chief circuit judge may appoint either the friend of the court or a licensed attorney to serve as a referee.”

Harvey v. Harvey, 680 N.W.2d 835 (Mich. 2004). · cites it 3× “If they elect this option, the circuit court may review the referee’s recommendation in accordance with MCL 552.507(5). That subsection provides that the circuit court “shall hold a de novo hearing on any matter that has been the subject of a referee hearing” if either party…”

Rivette v. Rose-Molina, 750 N.W.2d 603 (Mich. Ct. App. 2008). · cites it 2× “Within 21 days after a referee hearing, the referee must: (1) either make a statement of findings on the record or submit a written, signed report containing a summary of testimony and a statement of findings and (2) make a recommendation for an order and submit it to the court…”

Cochrane v. Brown, 592 N.W.2d 123 (Mich. Ct. App. 1999). · cites it 5× “Defendant contends that the trial court erred in simply adopting the referee’s findings of fact and recommendation without conducting its own hearing de novo.”

Heindlmeyer v. Ottawa Cnty. Concealed Weapons Licensing Bd., 707 N.W.2d 353 (Mich. Ct. App. 2005). · cites it 3× “” 4 Cochrane, Marshall, and Truitt all addressed MCL 552.507, which entitles a party to a hearing de novo in the circuit court on request of the party with respect to a challenge of a referee’s recommendation in a domestic relations matter, but which statute did not, at the time…”

Sturgis v. Sturgis, 840 N.W.2d 408 (Mich. Ct. App. 2013). · cites it 2× “MCL 552.507(4) provides: The court shall hold a de novo hearing on any matter that has been the subject of a referee hearing, upon the written request of either party or upon motion of the court.”

Dumm v. Brodbeck, 740 N.W.2d 751 (Mich. Ct. App. 2007). · cites it 3× “MCL 552.507 also permits judicial review of FOC recommendations following the objection of a party.”

Marshall v. Beal, 405 N.W.2d 101 (Mich. Ct. App. 1986). · cites it 2× “However, even if we assume that a friend of the court referee has the authority to conduct hearings and make recommendations regarding purely legal issues, it is clear from the statute that the circuit court must, upon motion by either party, conduct a "de novo hearing,” rather…”

Dobrzenski v. Dobrzenski, 528 N.W.2d 827 (Mich. Ct. App. 1995). · cites it 2× “I respectfully dissent, because I disagree with defendant's contention that he was entitled to an evidentiary hearing de novo before the circuit court.”

Truitt v. Truitt, 431 N.W.2d 454 (Mich. Ct. App. 1988). · cites it 2× “MCL 552.507(5); MSA 25.176(7)(5). The distinction is one that has meaning and, in the context of trials, has been extensively discussed by this Court in Walker v Wolverine Fabricating & Mfg Co, Inc, 138 Mich App 660 ; 360 NW2d 264 (1984), lv grtd 422 Mich 858 (1985), and in…”

Mead v. Batchlor, 460 N.W.2d 493 (Mich. 1990). “27 The authority to order a hearing before a referee, authorized by MCL 552.507; MSA 25.176(7), can not only save the time of the circuit court, but it often prompts payments: (2) A referee may do all of the following: (a) Hear all motions in a domestic relations matter, except…”

D'allessandro v. Ely, 434 N.W.2d 662 (Mich. Ct. App. 1988). · cites it 2× “On December 18, 1986, plaintiffs filed a motion in Cass Circuit Court pursuant to MCL 552.507(5); MSA 25.176(7)(5) for de novo review on the jurisdiction issue.”

Show all 63 citing cases →

— Mich. Comp. Laws § 552.507(1) — 4 cases

Harvey v. Harvey, 668 N.W.2d 187 (Mich. Ct. App. 2003). “§ 552.507(1), the chief circuit judge may appoint either the friend of the court or a licensed attorney to serve as a referee.”

Visser v. Visser, 299 Mich. App. 12 (Mich. Ct. App. 2012).

Monica Anne Mansfield v. Jason Douglas Mansfield (Mich. Ct. App. 2019).

Third Jud. Cir. Court v. Jud. Attys. Ass'n, 742 N.W.2d 127 (Mich. 2007).

— Mich. Comp. Laws § 552.507(2)(a) — 7 cases

Harvey v. Harvey, 668 N.W.2d 187 (Mich. Ct. App. 2003). “§ 552.507(1), the chief circuit judge may appoint either the friend of the court or a licensed attorney to serve as a referee.”

Visser v. Visser, 299 Mich. App. 12 (Mich. Ct. App. 2012).

Ryan Danelle Robinson v. Patrick Jerome Marculewicz (Mich. Ct. App. 2019).

Jill P Mitchell v. Bryan J Mitchell (Mich. Ct. App. 2020).

Yvette Jones v. Jeffrey Jones (Mich. Ct. App. 2022).

— Mich. Comp. Laws § 552.507(2)(b) — 1 case

Courtney Lynn Troost v. Sean Michael-Allen Troost (Mich. Ct. App. 2025).

— Mich. Comp. Laws § 552.507(2)(c) — 1 case

Harvey v. Harvey, 668 N.W.2d 187 (Mich. Ct. App. 2003). “§ 552.507(1), the chief circuit judge may appoint either the friend of the court or a licensed attorney to serve as a referee.”

— Mich. Comp. Laws § 552.507(2)(d) — 1 case

Harvey v. Harvey, 668 N.W.2d 187 (Mich. Ct. App. 2003). “§ 552.507(1), the chief circuit judge may appoint either the friend of the court or a licensed attorney to serve as a referee.”

— Mich. Comp. Laws § 552.507(4) — 36 cases

Sturgis v. Sturgis, 840 N.W.2d 408 (Mich. Ct. App. 2013). “MCL 552.507(4) provides: The court shall hold a de novo hearing on any matter that has been the subject of a referee hearing, upon the written request of either party or upon motion of the court.”

Rivette v. Rose-Molina, 750 N.W.2d 603 (Mich. Ct. App. 2008). “Within 21 days after a referee hearing, the referee must: (1) either make a statement of findings on the record or submit a written, signed report containing a summary of testimony and a statement of findings and (2) make a recommendation for an order and submit it to the court…”

Harvey v. Harvey, 668 N.W.2d 187 (Mich. Ct. App. 2003). “§ 552.507(1), the chief circuit judge may appoint either the friend of the court or a licensed attorney to serve as a referee.”

Dumm v. Brodbeck, 740 N.W.2d 751 (Mich. Ct. App. 2007). “MCL 552.507 also permits judicial review of FOC recommendations following the objection of a party.”

Quintelle Scout-Keatin Hamden v. Martin Dean Marrow II (Mich. Ct. App. 2018).

— Mich. Comp. Laws § 552.507(5) — 30 cases

Harvey v. Harvey, 668 N.W.2d 187 (Mich. Ct. App. 2003). “§ 552.507(1), the chief circuit judge may appoint either the friend of the court or a licensed attorney to serve as a referee.”

Harvey v. Harvey, 680 N.W.2d 835 (Mich. 2004). “If they elect this option, the circuit court may review the referee’s recommendation in accordance with MCL 552.507(5). That subsection provides that the circuit court “shall hold a de novo hearing on any matter that has been the subject of a referee hearing” if either party…”

Cochrane v. Brown, 592 N.W.2d 123 (Mich. Ct. App. 1999). “Defendant contends that the trial court erred in simply adopting the referee’s findings of fact and recommendation without conducting its own hearing de novo.”

Marshall v. Beal, 405 N.W.2d 101 (Mich. Ct. App. 1986). “However, even if we assume that a friend of the court referee has the authority to conduct hearings and make recommendations regarding purely legal issues, it is clear from the statute that the circuit court must, upon motion by either party, conduct a "de novo hearing,” rather…”

Dobrzenski v. Dobrzenski, 528 N.W.2d 827 (Mich. Ct. App. 1995). “I respectfully dissent, because I disagree with defendant's contention that he was entitled to an evidentiary hearing de novo before the circuit court.”

— Mich. Comp. Laws § 552.507(5)(a) — 2 cases

Noel David Waterbury v. Pamela Diane Waterbury (Mich. Ct. App. 2022).

Tyler James Fuller v. Makenna Emily Fuller (Mich. Ct. App. 2023).

— Mich. Comp. Laws § 552.507(5)(b) — 9 cases

Dumm v. Brodbeck, 740 N.W.2d 751 (Mich. Ct. App. 2007). “MCL 552.507 also permits judicial review of FOC recommendations following the objection of a party.”

Ryan Danelle Robinson v. Patrick Jerome Marculewicz (Mich. Ct. App. 2019).

Patricia Labarre v. Robert S Labarre (Mich. Ct. App. 2019).

Rachel Anne Butters v. Patrick Lee Butters (Mich. Ct. App. 2022).

— Mich. Comp. Laws § 552.507(6) — 8 cases

Heindlmeyer v. Ottawa Cnty. Concealed Weapons Licensing Bd., 707 N.W.2d 353 (Mich. Ct. App. 2005). “” 4 Cochrane, Marshall, and Truitt all addressed MCL 552.507, which entitles a party to a hearing de novo in the circuit court on request of the party with respect to a challenge of a referee’s recommendation in a domestic relations matter, but which statute did not, at the time…”

Noel David Waterbury v. Pamela Diane Waterbury (Mich. Ct. App. 2022).

Rachel Anne Butters v. Patrick Lee Butters (Mich. Ct. App. 2022).

Jeffrey Curtis Todd v. Nikki Leann Todd (Mich. Ct. App. 2023).

— Mich. Comp. Laws § 552.507(6)(a) — 11 cases

Noel David Waterbury v. Pamela Diane Waterbury (Mich. Ct. App. 2022).

Quintelle Scout-Keatin Hamden v. Martin Dean Marrow II (Mich. Ct. App. 2018).

Rachel Anne Butters v. Patrick Lee Butters (Mich. Ct. App. 2022).

— Mich. Comp. Laws § 552.507(6)(b) — 1 case

20241217_C371011_28_371011.Opn.Pdf (Mich. Ct. App. 2024).

— Mich. Comp. Laws § 552.507(6)(c) — 1 case

Monica Lynn O'Brien v. Matthew Joseph King (Mich. Ct. App. 2025).

Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.