Mich. Comp. Laws » Michigan Compiled Laws / Chapter 722 / Act 195 of 2001
Michigan Compiled Laws

Mich. Comp. Laws § 722.1207 (2026)

Determination of inconvenient forum.

✓ current as of July 2026
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UNIFORM CHILD-CUSTODY JURISDICTION AND ENFORCEMENT ACT


Act 195 of 2001


722.1207 Determination of inconvenient forum.

Sec. 207.

    (1) A court of this state that has jurisdiction under this act to make a child-custody determination may decline to exercise its jurisdiction at any time if it determines that it is an inconvenient forum under the circumstances and that a court of another state is a more appropriate forum. The issue of inconvenient forum may be raised upon the motion of a party, the court's own motion, or the request of another court.

    (2) Before determining whether it is an inconvenient forum, a court of this state shall consider whether it is appropriate for a court of another state to exercise jurisdiction. For this purpose, the court shall allow the parties to submit information and shall consider all relevant factors, including all of the following:

    (a) Whether domestic violence has occurred and is likely to continue in the future and which state could best protect the parties and the child.

    (b) The length of time the child has resided outside this state.

    (c) The distance between the court in this state and the court in the state that would assume jurisdiction.

    (d) The parties' relative financial circumstances.

    (e) An agreement by the parties as to which state should assume jurisdiction.

    (f) The nature and location of the evidence required to resolve the pending litigation, including the child's testimony.

    (g) The ability of the court of each state to decide the issue expeditiously and the procedures necessary to present the evidence.

    (h) The familiarity of the court of each state with the facts and issues of the pending litigation.

    (3) If a court of this state determines that it is an inconvenient forum and that a court of another state is a more appropriate forum, it shall stay the proceedings upon condition that a child-custody proceeding be promptly commenced in another designated state and may impose any other condition the court considers just and proper.

    (4) A court of this state may decline to exercise jurisdiction under this act if a child-custody determination is incidental to an action for divorce or another proceeding while still retaining jurisdiction over the divorce or other proceeding.

History: 2001, Act 195, Eff. Apr. 1, 2002

Notes of Decisions
Cited in 25 cases (11 in the last 5 years), 2003–2026 · leading case: Cheesman v. Williams, 874 N.W.2d 385 (Mich. Ct. App. 2015).
Sort: Relevance Newest Treatment
Cheesman v. Williams, 874 N.W.2d 385 (Mich. Ct. App. 2015). · cites it 18× “(b) A court of another state does not have jurisdiction under subdivision (a), or a court of the home state of the child has declined to exercise jurisdiction on the ground that this state is the more appropriate forum under [MCL 722.1207 or 722.1208], and the court finds both…”
Vidyaarthy C Ramamoorthi v. Chinnaiah Ramamoorthi, 918 N.W.2d 191 (Mich. Ct. App. 2018). · cites it 4× “Moreover, MCL 722.1207 specifically provides for bifurcation of a divorce proceeding and a custody proceeding under the *335 UCCJEA.”
White v. Harrison-White, 760 N.W.2d 691 (Mich. Ct. App. 2008). · cites it 2× “1202(l)(a) on the basis of either significant connection or substantial evidence, the court may decline to exercise its jurisdiction if it determines that it is an inconvenient forum under MCL 722.1207. MCL 722.1202(2). The trial court did not assess whether Michigan is an…”
Atchison v. Atchison, 664 N.W.2d 249 (Mich. Ct. App. 2003). “1202] or that a court of this state would be a more convenient forum under section 207 [MCL 722.1207], (b) A court of this state or a court of the other state determines that neither the child, nor a parent of the child, nor a person acting as a parent presently resides in the…”
Foster v. Wolkowitz, 785 N.W.2d 59 (Mich. 2010). “26 MCL 722.1207(1); 750 111 Comp Stat 36/207(a).”
Bryce Welling v. Jessica Welling (Mich. Ct. App. 2025). · cites it 15× “On March 5, 2025, the trial court issued an opinion and order concluding that Michigan 4 In his brief, plaintiff addressed the factors of MCL 722.1207, presenting a narrative argument.”
Jeremy Duane Willis v. Christelle Bianco Willis (Mich. Ct. App. 2022). · cites it 9× “The Kalamazoo Circuit Court subsequently entered a written opinion and order dismissing the matter based on the court’s decision to decline exercising jurisdiction over the matter under the UCCJEA.”
Rebecca Kay Richardson v. Cody James Snipes (Mich. Ct. App. 2026). · cites it 9× “DECLINING HOME-STATE JURISDICTION UNDER § 207: INCONVENIENT FORUM MCL 722.1207 allows a court to decline jurisdiction under certain circumstances.”
Tina Veneskey v. Michael Keith Sulier (Mich. Ct. App. 2021). · cites it 7× “1201(1), and that Michigan presented an inconvenient forum for resolution of the child custody dispute, MCL 722.1207. We conclude that the plaintiffs’ precipitous removal of the child from her residence in North Carolina and from the care of her stepfather shortly after the…”
Luke Nathaneal Bowman v. Chelsey Ann Bowman (Mich. Ct. App. 2016). · cites it 6× “-2- another state having jurisdiction substantially in conformity with this act, unless the proceeding has been terminated or is stayed by the court of the other state because a court of this state is a more convenient forum under [MCL 722.1207]. (2) Except as otherwise provided…”
Ariana Rosalie Omaits V Ryan Andrew Zerbe (Mich. Ct. App. 2022). · cites it 5× “(2) A court of this state that has exclusive, continuing jurisdiction under this section may decline to exercise its jurisdiction if the court determines that it is an inconvenient forum under [MCL 722.1207]. As an initial matter, respondent argues that the trial court erred by…”
Allison Smith v. Joshua Smith (Mich. Ct. App. 2022). · cites it 5× “We find no error warranting appellate relief because, assuming that the trial court had jurisdiction over the parties’ youngest child, AS, the trial court did not abuse its discretion by ruling that it would not exercise that jurisdiction.”
Show all 25 citing cases →
— Mich. Comp. Laws § 722.1207(1) — 5 cases
Cheesman v. Williams, 874 N.W.2d 385 (Mich. Ct. App. 2015). “(b) A court of another state does not have jurisdiction under subdivision (a), or a court of the home state of the child has declined to exercise jurisdiction on the ground that this state is the more appropriate forum under [MCL 722.1207 or 722.1208], and the court finds both…”
Foster v. Wolkowitz, 785 N.W.2d 59 (Mich. 2010). “26 MCL 722.1207(1); 750 111 Comp Stat 36/207(a).”
Tina Veneskey v. Michael Keith Sulier (Mich. Ct. App. 2021). “1201(1), and that Michigan presented an inconvenient forum for resolution of the child custody dispute, MCL 722.1207. We conclude that the plaintiffs’ precipitous removal of the child from her residence in North Carolina and from the care of her stepfather shortly after the…”
Ariana Rosalie Omaits V Ryan Andrew Zerbe (Mich. Ct. App. 2022). “(2) A court of this state that has exclusive, continuing jurisdiction under this section may decline to exercise its jurisdiction if the court determines that it is an inconvenient forum under [MCL 722.1207]. As an initial matter, respondent argues that the trial court erred by…”
Jeremy Duane Willis v. Christelle Bianco Willis (Mich. Ct. App. 2022). “The Kalamazoo Circuit Court subsequently entered a written opinion and order dismissing the matter based on the court’s decision to decline exercising jurisdiction over the matter under the UCCJEA.”
— Mich. Comp. Laws § 722.1207(2) — 9 cases
Cheesman v. Williams, 874 N.W.2d 385 (Mich. Ct. App. 2015). “(b) A court of another state does not have jurisdiction under subdivision (a), or a court of the home state of the child has declined to exercise jurisdiction on the ground that this state is the more appropriate forum under [MCL 722.1207 or 722.1208], and the court finds both…”
Rebecca Kay Richardson v. Cody James Snipes (Mich. Ct. App. 2026). “DECLINING HOME-STATE JURISDICTION UNDER § 207: INCONVENIENT FORUM MCL 722.1207 allows a court to decline jurisdiction under certain circumstances.”
Bryce Welling v. Jessica Welling (Mich. Ct. App. 2025). “On March 5, 2025, the trial court issued an opinion and order concluding that Michigan 4 In his brief, plaintiff addressed the factors of MCL 722.1207, presenting a narrative argument.”
Jeremy Duane Willis v. Christelle Bianco Willis (Mich. Ct. App. 2022). “The Kalamazoo Circuit Court subsequently entered a written opinion and order dismissing the matter based on the court’s decision to decline exercising jurisdiction over the matter under the UCCJEA.”
Luke Nathaneal Bowman v. Chelsey Ann Bowman (Mich. Ct. App. 2016). “-2- another state having jurisdiction substantially in conformity with this act, unless the proceeding has been terminated or is stayed by the court of the other state because a court of this state is a more convenient forum under [MCL 722.1207]. (2) Except as otherwise provided…”
— Mich. Comp. Laws § 722.1207(2)(a) — 1 case
Bryce Welling v. Jessica Welling (Mich. Ct. App. 2025). “On March 5, 2025, the trial court issued an opinion and order concluding that Michigan 4 In his brief, plaintiff addressed the factors of MCL 722.1207, presenting a narrative argument.”
— Mich. Comp. Laws § 722.1207(2)(b) — 1 case
Bryce Welling v. Jessica Welling (Mich. Ct. App. 2025). “On March 5, 2025, the trial court issued an opinion and order concluding that Michigan 4 In his brief, plaintiff addressed the factors of MCL 722.1207, presenting a narrative argument.”
— Mich. Comp. Laws § 722.1207(2)(c) — 1 case
Bryce Welling v. Jessica Welling (Mich. Ct. App. 2025). “On March 5, 2025, the trial court issued an opinion and order concluding that Michigan 4 In his brief, plaintiff addressed the factors of MCL 722.1207, presenting a narrative argument.”
— Mich. Comp. Laws § 722.1207(2)(d) — 1 case
Bryce Welling v. Jessica Welling (Mich. Ct. App. 2025). “On March 5, 2025, the trial court issued an opinion and order concluding that Michigan 4 In his brief, plaintiff addressed the factors of MCL 722.1207, presenting a narrative argument.”
— Mich. Comp. Laws § 722.1207(2)(e) — 1 case
Bryce Welling v. Jessica Welling (Mich. Ct. App. 2025). “On March 5, 2025, the trial court issued an opinion and order concluding that Michigan 4 In his brief, plaintiff addressed the factors of MCL 722.1207, presenting a narrative argument.”
— Mich. Comp. Laws § 722.1207(2)(f) — 1 case
Bryce Welling v. Jessica Welling (Mich. Ct. App. 2025). “On March 5, 2025, the trial court issued an opinion and order concluding that Michigan 4 In his brief, plaintiff addressed the factors of MCL 722.1207, presenting a narrative argument.”
— Mich. Comp. Laws § 722.1207(2)(h) — 1 case
Cheesman v. Williams, 874 N.W.2d 385 (Mich. Ct. App. 2015). “(b) A court of another state does not have jurisdiction under subdivision (a), or a court of the home state of the child has declined to exercise jurisdiction on the ground that this state is the more appropriate forum under [MCL 722.1207 or 722.1208], and the court finds both…”
— Mich. Comp. Laws § 722.1207(3) — 3 cases
Cheesman v. Williams, 874 N.W.2d 385 (Mich. Ct. App. 2015). “(b) A court of another state does not have jurisdiction under subdivision (a), or a court of the home state of the child has declined to exercise jurisdiction on the ground that this state is the more appropriate forum under [MCL 722.1207 or 722.1208], and the court finds both…”
Jose Guardalupe Hernandez v. Victoria Mayoral-Martinez (Mich. Ct. App. 2019).
Ariana Rosalie Omaits V Ryan Andrew Zerbe (Mich. Ct. App. 2022). “(2) A court of this state that has exclusive, continuing jurisdiction under this section may decline to exercise its jurisdiction if the court determines that it is an inconvenient forum under [MCL 722.1207]. As an initial matter, respondent argues that the trial court erred by…”
— Mich. Comp. Laws § 722.1207(4) — 3 cases
Vidyaarthy C Ramamoorthi v. Chinnaiah Ramamoorthi, 918 N.W.2d 191 (Mich. Ct. App. 2018). “Moreover, MCL 722.1207 specifically provides for bifurcation of a divorce proceeding and a custody proceeding under the *335 UCCJEA.”
Vidyaarthy C Ramamoorthi v. Chinnaiah Ramamoorthi (Mich. Ct. App. 2018).
Charlene Diane Dorais v. Gabor George Burt (Mich. Ct. App. 2023).
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