Mich. Comp. Laws » Michigan Compiled Laws / Chapter 722 / Act 91 of 1970
Michigan Compiled Laws

Mich. Comp. Laws § 722.24 (2026)

Child custody disputes; powers of court; appointment of lawyer-guardian ad litem.

✓ current as of July 2026
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CHILD CUSTODY ACT OF 1970


Act 91 of 1970


722.24 Child custody disputes; powers of court; appointment of lawyer-guardian ad litem.

Sec. 4.

    (1) In all actions involving dispute of a minor child's custody, the court shall declare the child's inherent rights and establish the rights and duties as to the child's custody, support, and parenting time in accordance with this act.

    (2) If, at any time in the proceeding, the court determines that the child's best interests are inadequately represented, the court may appoint a lawyer-guardian ad litem to represent the child. A lawyer-guardian ad litem represents the child and has powers and duties in relation to that representation as set forth in section 17d of chapter XIIA of 1939 PA 288, MCL 712A.17d. All provisions of section 17d of chapter XIIA of 1939 PA 288, MCL 712A.17d, apply to a lawyer-guardian ad litem appointed under this act.

    (3) In a proceeding in which a lawyer-guardian ad litem represents a child, he or she may file a written report and recommendation. The court may read the report and recommendation. The court shall not, however, admit the report and recommendation into evidence unless all parties stipulate the admission. The parties may make use of the report and recommendation for purposes of a settlement conference.

    (4) After a determination of ability to pay, the court may assess all or part of the costs and reasonable fees of the lawyer-guardian ad litem against 1 or more of the parties involved in the proceedings or against the money allocated from marriage license fees for family counseling services under section 3 of 1887 PA 128, MCL 551.103. A lawyer-guardian ad litem appointed under this section shall not be paid a fee unless the court first receives and approves the fee.

History: 1970, Act 91, Eff. Apr. 1, 1971 ;-- Am. 1996, Act 19, Eff. June 1, 1996 ;-- Am. 1998, Act 482, Eff. Mar. 1, 1999

Notes of Decisions
Cited in 42 cases (12 in the last 5 years), 1976–2026 · leading case: Grange Ins. Co of Michigan v. Edward Lawrence, 494 Mich. 475 (Mich. 2013).
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Grange Ins. Co of Michigan v. Edward Lawrence, 494 Mich. 475 (Mich. 2013). · cites it 2× “65 Absent an express indication that the Legislature intended a different result, we will not presume that the Legislature intended to modify the common-law rule applicable to children and adults alike that a person may have only a single domicile at a given point in time.”
In Re Kh, 677 N.W.2d 800 (Mich. 2004). · cites it 2× “See MCL 722.24. However, the majority finds that the best interests control when there is a custody dispute between two legal parents, but not when a dispute *810 involves a putative parent.”
Van v. Zahorik, 597 N.W.2d 15 (Mich. 1999). · cites it 2× “" Therefore, the Child Custody Act is the exclusive means for pursuing such rights. In addition to addressing child custody disputes between parents and between a parent and state agency, the Child Custody Act specifically addresses the rights of certain other parties, e.”
In Re Clausen, 502 N.W.2d 649 (Mich. 1993). · cites it 2× “Basically, the next friend advances three theories on which a child is entitled to bring such an action.”
Killingbeck v. Killingbeck, 711 N.W.2d 759 (Mich. Ct. App. 2006). · cites it 2× “; MCL 722.24(1). [24] Aichele, supra at 167 , 673 N.”
Harvey v. Harvey, 680 N.W.2d 835 (Mich. 2004). “” MCL 722.24(1); Van, supra at 328 . Taken together, these statutory provisions impose on the trial court the duty to ensure that the resolution of any custody dispute is in the best interests of the child.”
In Re Weldon, 244 N.W.2d 827 (Mich. 1976). · cites it 2× “MCLA 722.24; MSA 25.312(4) says in all such actions the circuit court "shall declare the inherent rights of the child and establish the rights and duties as to custody, support and visitation of the child in accordance with this act".”
Bowie v. Arder, 490 N.W.2d 568 (Mich. 1992). “[MCL 722.24; MSA 25.312(4). Emphasis added.”
Brecht v. Hendry, 825 N.W.2d 110 (Mich. Ct. App. 2012). “” MCL 722.24(1). Moreover, after a Michigan court has entered a judgment or order governing child custody, the court retains jurisdiction over the child and may modify its order or judgment until the child reaches — at the latest — age 19 years and six months.”
Hutchins v. Hutchins, 269 N.W.2d 539 (Mich. Ct. App. 1978). · cites it 2× “This standard applies not only in the original divorce proceeding but also in all actions involving a dispute of custody of a minor child, see MCL 722.24; MSA 25.312(4). The trial judge's opinion does not indicate that he used this standard in determining whether, in the…”
Henry v. Henry, 326 N.W.2d 497 (Mich. Ct. App. 1982). · cites it 2× “The Court observed that "[t]his standard applies not only in the original divorce proceeding but also in all actions involving a dispute of custody of a minor child, see MCL 722.24; MSA 25.312(4).” Id., 238 . This view of the law was adopted by a majority of the Court in Watters…”
Anita L Sheardown v. Janine Guastella, 920 N.W.2d 172 (Mich. Ct. App. 2018). “I cannot countenance such a result, particularly in light of the controlling United States Supreme Court precedent recognizing the right of same-sex couples to marry and to avail themselves of the concomitant benefits, and for the reasons set forth below, I would reverse and…”
Show all 42 citing cases →
— Mich. Comp. Laws § 722.24(1) — 18 cases
Grange Ins. Co of Michigan v. Edward Lawrence, 494 Mich. 475 (Mich. 2013). “65 Absent an express indication that the Legislature intended a different result, we will not presume that the Legislature intended to modify the common-law rule applicable to children and adults alike that a person may have only a single domicile at a given point in time.”
Killingbeck v. Killingbeck, 711 N.W.2d 759 (Mich. Ct. App. 2006). “; MCL 722.24(1). [24] Aichele, supra at 167 , 673 N.”
Harvey v. Harvey, 680 N.W.2d 835 (Mich. 2004). “” MCL 722.24(1); Van, supra at 328 . Taken together, these statutory provisions impose on the trial court the duty to ensure that the resolution of any custody dispute is in the best interests of the child.”
Brecht v. Hendry, 825 N.W.2d 110 (Mich. Ct. App. 2012). “” MCL 722.24(1). Moreover, after a Michigan court has entered a judgment or order governing child custody, the court retains jurisdiction over the child and may modify its order or judgment until the child reaches — at the latest — age 19 years and six months.”
Van v. Zahorik, 597 N.W.2d 15 (Mich. 1999). “" Therefore, the Child Custody Act is the exclusive means for pursuing such rights. In addition to addressing child custody disputes between parents and between a parent and state agency, the Child Custody Act specifically addresses the rights of certain other parties, e.”
— Mich. Comp. Laws § 722.24(2) — 7 cases
Beverley Nettles v. Daniel E Nickerson Jr (Mich. Ct. App. 2016).
in Re Harbert Minors (Mich. Ct. App. 2016).
Jennifer Renee Echols v. Julien Quincy-Wycliff Kabza (Mich. Ct. App. 2021).
Christopher Jon Mildenberg v. Sarah Elizabeth Mildenberg (Mich. Ct. App. 2022).
Meghan Marie Kuebler v. Paul Andrew Kuebler (Mich. Ct. App. 2023).
— Mich. Comp. Laws § 722.24(3) — 4 cases
Christopher Jon Mildenberg v. Sarah Elizabeth Mildenberg (Mich. Ct. App. 2022).
Meghan Marie Kuebler v. Paul Andrew Kuebler (Mich. Ct. App. 2023).
Ewelina Franciszka Skowron v. Mariusz MacIej Skowron (Mich. Ct. App. 2025).
Jennifer Renee Echols v. Julien Quincy-Wycliff Kabza (Mich. Ct. App. 2021).
— Mich. Comp. Laws § 722.24(c) — 1 case
Brooke Krueger v. Trevor John Curler (Mich. Ct. App. 2026).
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