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If you or your child have experienced significant domestic violence and are wondering how it will affect child custody in Arizona, you will need to know the laws concerning domestic violence and child custody in Arizona.
Fortunately, the Arizona Court of Appeals in the published decision of In Re Marriage of Morris & Mandel provided insight into determining how domestic violence affects child custody matters in Arizona.
Mother and Father had one minor child (“Child”) during their marriage. Child was born in Arizona in 2019. In June 2020 Mother filed for dissolution of marriage in Arizona while Mother, Father, and Child were still living in Arizona.
In lieu of the final divorce decree, Mother filed a motion with the Arizona Superior Court to obtain emergency temporary child custody orders. In the motion, Mother claimed Father had engaged in significant domestic violence against Mother.
Mother, a member of the United States military, sought permission to relocate to South Korea with Child for Mother’s military deployment.
Mother’s allegations of domestic violence were based, in part, on an incident in 2018 where Father had pled guilty to criminal charges. However, those criminal charges were later dismissed because Father attended a diversion program in exchange for dismissal of the charges.
In 2019 Father was jailed for committing domestic violence against Mother. Mother then obtained orders of protection against Father in 2019 and 2020.
Both orders of protection were affirmed after contested hearings. In anticipation of Child’s birth in 2019, Mother dismissed the 2019 order of protection to allow Father to be present during Child’s birth.
In July 2020 the Arizona Superior Court granted sole legal decision making to Mother in its temporary orders. The Arizona Superior Court declared Mother had “shown by a preponderance of the evidence that there had been a significant history of domestic violence.”
The Arizona Superior Court “concluded that ‘an award of joint legal decision-making [was] barred by A.R.S. § 25-403.03(A).’” The Arizona Superior Court also awarded Mother with primary parenting time and granted Father daily video calls and parenting time with Child in South Korea during Mother’s leave.
“Over the next two years, while the divorce was pending, Mother left the military, returned from South Korea and moved to Massachusetts.” Father moved to South Carolina. In May 2022 the Arizona Superior Court issued a final divorce decree. The Arizona Superior Court’s final decree awarded the parties with joint legal decision-making.
The Arizona Superior Court also entered a parenting plan designating Mother as the primary residential parent, with an increase in Father’s parenting time once Child began kindergarten.
Mother appealed, among other things, the legal decision-making and parenting time decisions of the court.
Legal Decision Making Standard of Review
On appeal, Mother argued that the Arizona Superior Court lacked the authority to grant Father joint legal decision making once it found Father had engaged in significant domestic violence.
The Arizona Court of Appeals reviews legal decision-making orders for an abuse of discretion. Engstrom v. McCarthy, 243 Ariz. 469, ¶ 4 (App. 2018). “An abuse of discretion occurs when the court commits an error of law in reaching a discretionary conclusion or when the record lacks competent evidence to support the decision.” Id.
Arizona Laws on Legal Decision Making When Domestic Violence Occurs
A.R.S. § 25-403.03 is the Arizona statute governing legal decision-making in situations where domestic violence has occurred. A.R.S. § 25-403.03(A) states: regardless of subsection (D) of this section, joint legal decision-making shall not be awarded if:
- The court makes a finding of the existence of significant domestic violence pursuant to A.R.S. § 13-3601; or,
- The court finds by a preponderance of the evidence that there has been a significant history of domestic violence.
“Preponderance of the evidence” means more likely than not. On a percentage scale, greater than 50%.
A.R.S. § 25-403.03(D) states: If the court determines that a parent who is seeking sole or joint legal decision-making has committed an act of domestic violence against the other parent, there is a rebuttable presumption that an award of sole or joint legal decision-making to the parent who committed the act of domestic violence is contrary to the child’s best interests.
This presumption, however, does not apply if both parents have committed an act of domestic violence. For the purposes of this subsection, a person commits an act of domestic violence if that person does any of the following:
- Intentionally, knowingly, or recklessly causes or attempts to cause sexual assault or serious physical injury.
- Places a person in reasonable apprehension of imminent serious physical injury to any person.
- Engages in a pattern of behavior for which a court may issue an ex parte order to protect the other parent who is seeking child custody or to protect the child and the child’s sibling.
The term “rebuttable presumption” means a court is required to reach a specific factual or legal conclusion unless contradictory evidence can satisfactorily prove otherwise.
A.R.S. § 25-403.03(E) states: to determine if the parent has rebutted the presumption of § 25-403.03(D) the court shall consider all of the following:
- Whether the parent has demonstrated that being awarded sole or joint legal decision-making or substantially equal parenting time is in the child’s best interests.
- Whether the parent has successfully completed a batterer’s prevention program.
- Whether the parent has successfully completed a program of alcohol or drug abuse counseling, if the court determines that counseling is appropriate.
- Whether the parent has successfully completed a parenting class, if the court determines that a parenting class is appropriate.
- If the parent is on probation, parole or community supervision, whether the parent is restrained by a protective order that was granted after a hearing.
- Whether the parent has committed any further acts of domestic violence.
Legal Definition of “Significant” Domestic Violence in Arizona
Note that § 25-403.03(A) references § 13-3601 to express what constitutes domestic violence for purposes of subsection (A). The term “significant”, as used in that section, does not have a precise legal definition in Arizona. Upon passage of 25-403.03(A), the Arizona legislature failed to define the term “significant.” See A.R.S. § 25-401 (“Definitions”).
An Arizona court may decide that one act of domestic violence qualifies as “significant” domestic violence due to the magnitude of violence involved.
On the other hand, an Arizona court could also conclude that numerous less serious acts of domestic violence qualify as a “significant history” of domestic violence due to the sheer number of incidents. In sum, the “significance” of domestic violence is determined on a case-by-case basis.
However, in the published decision of Deluna v. Petitto, 247 Ariz. 420 (App. 2019) the Arizona Superior Court defined “significance” under § 25-403.03(A) as a product of three factors. DeLuna, 247 Ariz. at 424, ¶ 15 n.6 (App. 2019). The three factors used in Deluna are: (1) the seriousness of the particular incident(s) of domestic violence, (2) the frequency or pervasiveness of the domestic violence, and (3) the passage of time and its impact on the victim. Id.
In Deluna the Arizona Superior Court used the three-factor test to determine whether a father’s domestic violence was “significant” for purposes of § 25-403.03(A). Id.
On appeal, the Arizona Court of Appeals in Deluna stated in its footnotes that the Arizona Superior Court’s use of the three-factor test “seemed reasonable.” Id.
The Arizona Court of Appeals in Deluna concluded the Arizona Superior Court’s use of the three-factor test was not an abuse of discretion because the Arizona Superior Court had “discretion to weigh the evidence and determine the degree of the domestic violence’s ‘significance’ for the purpose of § 25-403.03(A).” Id.
Although the Arizona Court of Appeals in Deluna did not declare the three-factor test as the end-all-be-all test for “significance,” the Arizona Court of Appeals did not disavow use of the test.
Subsequent cases presented to the Arizona Court of Appeals involving issues of “significance” under § 25-403.03(A) have similarly followed suit. See, e.g., Lopez v. Scimone, 1 CA-CV 21-0220 FC, ¶ 9 (Ariz. App. May 31, 2022) (mem. decision) (concluding the Superior Court’s use of the three-factor test to determine “significance” was not an abuse of discretion simply because the test was not mandated by the legislature); Paredes-Gabriel v. Riva, 1 CA-CV 18-0328 FC, 2019 WL 1959588, at *4, ¶ 18 (Ariz. App. May 2, 2019) (mem. decision) (not expressly rejecting Superior Court’s use of the three-factor test to conclude father committed significant domestic violence but reversing that conclusion on other grounds); Ferrell v. Myers, 1 CA-CV 21-0500 FC, ¶ 11 (Ariz. App. May 12, 2022) (mem. decision) (concluding Superior Court’s use of the three-factor test to determine whether domestic violence was significant is not required but also not reversible error); Brumley v. Brumley, 1 CA-CV 17- 0498 FC, 2018 WL 2208037, at *3, ¶ 17 (Ariz. App. May 5, 2018) (mem. decision) (affirming Superior Court’s conclusion that father’s domestic violence was not significant based on the three-factor test); Rodriguez v. Reynolds, 1 CA-CV 21-0044 FC, ¶ 12 (Ariz. App. October 7, 2021) (mem. decision) (concluding Superior Court’s use of the three-factor test was appropriate in determining father’s domestic violence was significant).
Notice the cited cases following Deluna’s three-part test for determining “significance” are unpublished memorandum decisions.
In short, unpublished memorandum decisions have limited precedential value.
More simply, lawyers and non-lawyers alike should not support legal arguments using unpublished memorandum decisions unless expressly permitted by rule. See Ariz. R. Sup. Ct. 111(c).
In the rare instance where courts allow unpublished memorandum decisions to be presented, such decisions only hold persuasive value, meaning courts don’t have to abide by them.
Luckily Deluna itself is a published opinion, and one can observe the Arizona Court of Appeals has consistently refused to overturn decisions using the Deluna test, based solely on the use of the Deluna test.
Although the Arizona Court of Appeals has never directly adopted the Deluna test or required courts to use the Deluna test, the Deluna opinion nevertheless contains valuable insight.
At the very minimum, the Deluna test is helpful in defining what “significant” domestic violence is in Arizona and what a “significant history” of domestic violence is in Arizona.
Applying A.R.S. § 25-403.03(A) & (D)
“When the trial court finds a parent has committed an act of domestic violence against the other parent, subsection (D) creates ‘a rebuttable presumption that an award of sole or joint legal decision-making to the parent who committed the act of domestic violence is contrary to the child’s best interest.’” See § 25-403.03(D).
However, when an Arizona court finds “significant domestic violence” or a “significant history of domestic violence” joint legal decision-making cannot be awarded. See § 25-403.03(A).
On appeal, Father did not challenge the Arizona Superior Court’s finding that Father had engaged in a significant history of domestic violence. Given that finding, the Arizona Court of Appeals declared the Arizona Superior Court was precluded from awarding joint legal decision-making.
The Arizona Court of Appeals proclaimed the Arizona Superior Court incorrectly analyzed the legal decision-making matter, using the standard which applied when domestic violence was not “significant.”
That is, the Arizona Superior Court mistakenly used § 25-403.03(D) when it should have used § 25-403.03(A) to reach its conclusion on legal decision-making.
The starting point for analyzing legal decision-making where domestic violence has occurred is § 25-403.03(A).
The next logical step if, and only if, there is not significant domestic violence and no significant history of domestic violence is § 25-403.03(D).
Since the Arizona Superior Court disregarded § 25-403.03(A) after finding Father had a significant history of domestic violence, it was reversible error for the Arizona Superior Court to award joint legal decision-making based on the conclusion Father had rebutted the presumption “against an award of legal decision making.”
Father contends the conclusion of the Arizona Court of Appeals is unreasonable, relying on the Arizona Superior Court’s “extensive findings that [Father] had rebutted the presumption and that joint legal decision-making was in [Child’s] best interest.”
Father also claims the conclusion of the Arizona Court of Appeals is unfair as a matter of public policy.
Father reasons “it is unfair to preclude a parent who has committed significant domestic violence or has a significant history of domestic violence from exercising joint legal decision-making.”
However, “[t]hese arguments are foreclosed by the language of § 25-403.03(A).” “When the statute is clear and unambiguous, we must apply its terms without further analysis.” JH2K I LLC v. Ariz. Dep’t of Health Servs., 246 Ariz. 307, ¶ 9 (App. 2019).
The Arizona Court of Appeals proceeded to vacate the award of joint legal decision-making and remanded the issue back to the Arizona Superior Court with instructions to award Mother with sole legal decision-making.
Parenting Time Standard of Review
Mother argues the Arizona Superior Court “improperly increased [Father’s] parenting time once Child started kindergarten.” Parenting time orders in Arizona are reviewed under an abuse of discretion standard. Engstrom at 469, ¶ 4.
Arizona Parenting Time Laws When Domestic Violence Occurs
The Arizona statute governing parenting time in situations where domestic violence has occurred is A.R.S. § 25-403.03(F).
Under § 25-403.03(F), if an Arizona court finds a parent has committed an act of domestic violence, the offending parent has the burden of proving that “parenting time will not endanger the child or significantly impair the child’s emotional development.”
If the parent meets this burden to the court’s satisfaction, the court shall place conditions on parenting time that best protect the child and the other parent from further harm. Such conditions may include:
- Requiring that an exchange of the child must occur in a protected setting as specified by the court.
- Requiring that an agency specified by the court must supervise parenting time. If the court allows a family or household member to supervise parenting time, the court shall establish conditions that this person must follow during parenting time.
- Requiring the parent who committed the act of domestic violence to attend and complete, to the court’s satisfaction, a program of intervention for perpetrators of domestic violence and any other counseling the court orders.
- Requiring the parent who committed the act of domestic violence to abstain from possessing or consuming alcohol or controlled substances during parenting time and for twenty-four hours before parenting time.
- Requiring the parent who committed the act of domestic violence to pay a fee for the costs of supervised parenting time.
- Prohibit overnight parenting time.
- Requiring a bond from the parent who committed the act of domestic violence for the child’s safe return.
- Requiring that the address of the child and the other parent remain confidential.
- Any other condition that the court determines is necessary to protect the child, the other parent and any other family or household member.
Under A.R.S. § 25-403(A) an Arizona court must determine parenting time “in accordance with the best interest of the child.” The court shall consider all factors that are relevant to the child’s physical and emotional well-being, including:
- The past, present and potential future relationship between the parent and the child.
- The interaction and interrelationship of the child with the child’s parent or parents, the child’s siblings and any other person who may significantly affect the child’s best interest.
- The child’s adjustment to home, school and community.
- If the child is of suitable age and maturity, the wishes of the child as to legal decision-making and parenting time.
- The mental and physical health of all individuals involved.
- Which parent is more likely to allow the child frequent, meaningful and continuing contact with the other parent. This paragraph does not apply if the court determines that a parent is acting in good faith to protect the child from witnessing an act of domestic violence or being a victim of domestic violence or child abuse.
- Whether one parent intentionally misled the court to cause an unnecessary delay, to increase the cost of litigation or to persuade the court to give a legal decision-making or a parenting time preference to that parent.
- Whether there has been domestic violence or child abuse pursuant to § 25-403.03.
- The nature and extent of coercion or duress used by a parent in obtaining an agreement regarding legal decision-making or parenting time.
- Whether a parent has complied with chapter 3, article 5 of this title (A.R.S. §§ 25-351 to 25-355).
- Whether either parent was convicted of an act of false reporting of child abuse or neglect under A.R.S. § 13-2907.02.
Under § 25-403.03(B) “[t]he court shall consider evidence of domestic violence as being contrary to the best interests of the child.”
“The court shall consider the safety and well-being of the child and of the victim of the act of domestic violence to be of primary importance.” “The court shall consider a perpetrator’s history of causing or threatening to cause physical harm to another person.”
Applying A.R.S. § 25-403.03 & § 25-403
Under the Arizona Superior Court’s order Father would “exercise parenting time for two continuous weeks at the end of each calendar quarter.” “Once kindergarten began, [Father’s] parenting time would increase to eight weeks in the summer, plus half of Christmas break and one week at spring break.” “In addition, the Arizona Superior Court allowed Father up to one week of parenting time per month in Mother’s state of residence.”
“[Mother’s] argument is premised in part on [Father’s] history of domestic violence.” “Unlike with legal decision-making, our statutory scheme does not prohibit parenting time for a parent who has engaged in ‘significant domestic violence’ or [who has] a ‘significant history of domestic violence.’” “Rather, parents who have committed domestic violence – ‘significant’ or otherwise – must ‘prove to the court’s satisfaction that parenting time will not endanger the child or significantly impair the child’s emotional development.’” See § 25-403.03(F). “If the parent does so … conditions [shall be placed] on parenting time that best protect the child and the other parent.” Id. “The statute does not specify the conditions, but it provides that the court ‘may’ issue certain orders, such as (1) requiring exchanges to occur in protected settings; (2) requiring the perpetrator to complete an intervention program; (3) prohibiting the perpetrator from consuming drugs or alcohol during parenting time; or (4) ‘imposing any other condition that the court determines is necessary to protect the child, the other parent and any other family or household member.’” Id.
“As with all parenting-time decisions, Arizona court‘s must also conduct a best-interest analysis under § 25-403.”
One factor to be considered in a best-interest analysis is domestic violence and child abuse. See § 25-403(A)(8). Arizona court‘s must consider domestic violence as contrary to a child’s best interest, and must consider the child and victim’s safety to be “of primary importance.” See A.R.S. 25-403.03(B).
Domestic violence is also relevant to other enumerated factors. See, e.g., § 25-403(A)(1) (“past, present and potential future relationship between the parent and child”), (A)(5) (“mental and physical health of all individuals involved”).
Arizona court’s must make specific findings on the record for every factor. Hart v. Hart, 220 Ariz. 183, ¶ 9 (App. 2009).
Here, the Arizona Superior Court mistakenly failed to engage in a best interest analysis concerning Father’s parenting time with Child.
However, the Arizona Court of Appeals noted the Arizona Superior Court implicitly addressed the requirements of § 25-403.03(F).
The Arizona Superior Court made findings regarding Father’s past domestic violence but found Child “had [a] good relationships with both parents.”
Additionally, Father had completed a batterer’s prevention course.
The Arizona Court of Appeals acknowledged these findings were supported by the record.
On the other hand, the Arizona Superior Court’s record reflects Mother had withheld parenting time from Father and had misled the Arizona Superior Court concerning the whereabouts of Child.
Based on the record, the Arizona Superior Court necessarily found that parenting time with Father would not endanger Child or significantly impair Child’s emotional development.
The Arizona Court of Appeals also gave weight to the fact “the parties had agreed Father could exercise unsupervised parenting time, the domestic violence had occurred years earlier, and Child was physically and mentally healthy.” “In addition, Mother proposed a parenting plan that allowed [Father] to exercise parenting time.”
The Arizona Superior Court “also addressed conditions that may be imposed under § 25-403.03(F).”
Father’s completion of the batterer’s prevention course satisfies a condition of § 25-403.03(F). Communications were also limited during exchanges. See § 25-403.03(F)(1), F(9). “Expressly citing A.R.S. § 25-403(F) in this analysis would have been a better practice.” “But because the court substantively addressed it, doing so implicitly was sufficient.”
“The [Arizona Superior] [C]ourt reasonably recognized that as children enter school, parenting-time arrangements must account for school schedules.” “The two-weeks-per-quarter arrangement for Child’s pre-kindergarten years would not work with most school calendars.” “As a result, the Arizona Superior Court crafted a schedule that would comply.” “[Mother] has also pointed to no authority that precludes a court from gradually increasing a parent’s parenting time.” “Rather, the increase comports with the public policy that absent evidence to the contrary, it is in a child’s best interests to have ‘substantial, frequent, meaningful, and continuing’ parenting time with both parents.” See A.R.S. § 25-103(B)(1).
Significant domestic violence or a significant history of domestic violence bars an offending parent from obtaining joint legal decision-making in Arizona. “Significance” may be determined using the Deluna test.
Where domestic violence by a parent is not significant, § 25-403.03(D) creates a rebuttable presumption against joint legal decision-making.
The presumption can be rebutted by showing joint legal decision-making is in the child’s best interest.
Regarding domestic violence and parenting time, it is in a child’s best interests to have “substantial, frequent, meaningful, and continuing” parenting time with both parents.
A parent who has committed domestic violence, significant or otherwise, can still exercise parenting time after showing the court that parenting time will not endanger the child or significantly impair the child’s emotional development. The offending parent must also show the court that parenting time is in the child’s best interest.
Arizona Child Custody Attorneys
If you have questions about child custody laws in Arizona, you should seriously consider contacting the attorneys at Hildebrand Law, PC. Our Arizona divorce and family law attorneys have over 100 years of combined experience successfully representing clients in divorce and family law cases.
Our family law firm has earned numerous awards such as US News and World Reports Best Arizona Family Law Firm, US News and World Report Best Divorce Attorneys, “Best of the Valley” by Arizona Foothills readers, and “Best Arizona Divorce Law Firms” by North Scottsdale Magazine.
Call us today at (480)305-8300 or reach out to us through our appointment scheduling form to schedule your personalized consultation and turn your child custody or family law case around today.
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