Wolfe v. Howatt

Plaintiff appeals as of right a September 3, 1981, lower court order granting custody of the parties’ minor child to defendant and permitting her to remove the child to Illinois. Upon a review of the record, we are convinced that we must remand for supplementation of the record for four reasons.

First, MCL 722.23; MSA 25.312(3) presents 11 factors that a trial judge must consider in determining the "best interests of the child”. Each factor must be individually considered. Lustig v Lustig, 99 Mich App 716, 731; 299 NW2d 375 (1980). Factor (j) was added to the statute effective January 14,…