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Riordan v. Kangas
Court of Appeals of Arizona · 2026-06-12
In this divorce case, Tara Kangas (Mother) appealed a Maricopa County superior court dissolution decree involving her young son with ex-husband Matthew Riordan (Father). The superior court denied Mother’s petition to relocate the child to Alaska, designated Father as the primary residential parent if she stayed there, and limited her parenting time to two six-week periods annually in Alaska, while ordering her to cover travel costs. The Arizona Court of Appeals affirmed the travel-cost allocation and other unaffected portions of the decree but vacated the relocation denial and parenting-time orders, remanding for further proceedings. The court reasoned that the superior court failed to make required specific findings under A.R.S. §§ 25-403(A), -403(B), -408(I), and -403.02(C)(3) explaining how its decisions served the child’s best interests, improperly relied on the possibility of Mother returning to Arizona despite her contrary testimony, and did not fully address all statutory relocation and parenting factors or include a holiday schedule.
family law
Klatt v. Sunbird
Court of Appeals of Arizona · 2026-06-11
In Klatt v. Sunbird Golf Resort Homeowners Association, homeowner Jimmie Klatt sued the Association after it amended the 2015 CC&Rs to create a $300 capital improvement assessment payable by future lot buyers, with the funds usable to maintain or improve the separately owned SunBird Golf Course. The superior court granted summary judgment to Klatt and declared the amendment void. The Arizona Court of Appeals affirmed, holding that the amendment was not reasonably foreseeable under the 2015 CC&Rs, which expressly excluded the golf course from association responsibilities and common-area expenses. The court further ruled that Klatt had standing and raised a justiciable controversy because the change affected the marketability of his property and created new financial ties between the Association and the golf course, in line with the foreseeability requirement established in Kalway v. Calabria Ranch HOA.
propertyprocedure
State v. Moninger
Court of Appeals of Arizona · 2026-05-29
In this case, Kevin Moninger was convicted of luring a minor for sexual exploitation after exchanging messages with an undercover police officer posing as a 13-year-old girl and driving to a planned meeting, leading the trial court to designate the offense as a dangerous crime against children (DCAC) and impose a seven-year prison term. On appeal, Moninger challenged the DCAC enhancement on the ground that no actual minor was involved. The Arizona Court of Appeals affirmed the sentence, holding that the enhancement was proper under the luring statute, A.R.S. § 13-3554. The court relied on the Arizona Supreme Court’s recent decision in State v. Marner, which clarified that neither the luring statute nor the DCAC sentencing provisions require an actual minor victim because the law targets solicitation conduct to protect children as a class.
criminal law
Leigh v. Chavez
Court of Appeals of Arizona · 2026-05-29
In Leigh v. Chavez, the Arizona Court of Appeals reviewed a Maricopa County superior court order arising from Mother Claryn Leigh’s petition to establish legal decision-making, parenting time, and child support for the parties’ child born in 2016. The superior court awarded Mother sole legal decision-making, required Father Rico Chavez’s parenting time to be supervised due to concerns about his home safety and mental fitness, and ordered him to pay $417 monthly in child support. On appeal, Father challenged the sufficiency of the evidence, the court’s decision not to appoint a court-appointed advisor, its weighing of evidence regarding incidents involving the child, and the conditioning of tax exemptions on child-support compliance. The Court of Appeals affirmed, holding that the absence of a trial transcript required it to presume the evidence supported the superior court’s findings under A.R.S. § 25-403, that Father had not shown a due-process violation or improper disregard of evidence, and that the tax-exemption condition was permitted by the Child Support Guidelines.
family law
Griffith v. Bennett
Court of Appeals of Arizona · 2026-05-28
In Griffith v. Bennett, Daniel Griffith appealed the Coconino County Superior Court’s dismissal of his petition for dissolution of marriage, legal decision-making, and parenting time concerning the parties’ minor child, born in 2023. The core dispute involved whether Arizona or the Navajo Nation had jurisdiction under the UCCJEA, which turns on identifying the child’s “home state” based on where the child lived with a parent for at least six consecutive months before the proceeding began. The superior court dismissed the petition without an evidentiary hearing, relying on the Navajo Nation court’s earlier protection order and concluding that Father had waived objections by not appearing there. The Arizona Court of Appeals vacated the dismissal and remanded, holding that the superior court must first resolve the disputed facts about the child’s residence to determine home-state jurisdiction, rather than deferring based on the other court’s actions or forum convenience, and must separately address marital and property issues under applicable standards.
family law
State v. Blackwell
Court of Appeals of Arizona · 2026-05-20
The case concerned whether a judge or jury must decide if Robert Blackwell’s multiple prior felony offenses were committed on the “same occasion” under A.R.S. § 13-703(L), which determines whether they count as separate historical prior felony convictions for sentencing enhancement as a repetitive offender. The superior court denied the State’s motion to have a judge resolve the issue based on court records alone and scheduled a jury trial; the State then sought special action review. The Court of Appeals accepted jurisdiction but denied relief, holding that under Apprendi v. New Jersey and Erlinger v. United States, any factual finding beyond the mere existence of a prior conviction—including the same-occasion inquiry based on timing, location, and other circumstances—must be submitted to a jury and proved beyond a reasonable doubt. The court rejected the State’s arguments for an efficiency exception or that guilty pleas or objective records could bypass the jury requirement.
criminal lawprocedure