Cited by

¶ 17 (App. 2021); see also Diezsi, 201 Ariz. at 526, ¶ 5 (findings required whether granting or denying petition).

The requirement for specific best-interests findings cannot be waived.2 ¶ 17 (App. 2021); -73, ¶¶ 7-10 (App. 2013).

“This statutory requirement cannot be satisfied by inference from a court’s order or waived by a party.” ¶ 17 (App. 2021).

¶ 17 (App. 2021); ¶ 5 (App. 2002) (findings required whether granting or denying petition).

¶ 17 (App. 2021) (as amended); ¶ 5 (App. 2002).

¶ 14 (App. 2021); ¶ 9 (App. 2019).

¶¶ 15–16 (App. 2021) (holding those findings are required when denying offending parent’s request for legal decision-making); DeLuna, 247 Ariz. at 423 ¶ 17 (holding same when granting such a request).

¶ 14 (App. 4 KRAKANA v. HADDEN Decision of the Court 2021); ¶ 9 (App. 2019).

Id.; (“[T]he statute explicitly invites the offending parent to present evidence of a change in circumstances.”).

§§ 25-403 and -409,” and to correct the court’s failure “to make the required findings regarding whether Father rebutted the statutory presumption.” ¶¶ 24-25 (App. 2021).

¶ 14 (App. 2021); ¶ 9 (App. 2019).

4 MARLOWE v. MICKELSEN Decision of the Court ¶14 Father, nonetheless, argues the superior court should have allowed him to present evidence on the best-interests factors to rebut § 25- 403.03.D’s presumption against awarding him sole or joint legal decision- making, ¶ 23 (App. 2021).

(child support); ¶ 14 (App. 2021) (legal decision-making); ¶ 9 (App. 2019) (parenting time).

¶ 14 (App. 2021); ¶ 9 (App. 2019).

EORGINA L. v. LYNDA R., et al. Decision of the Court ¶11 The doctrine of issue preclusion “precludes relitigating an issue of fact in a later case when, in a previous case, the same issue was actually litigated, a final judgment was entered, and the party against whom the doctrine is to be invoked had a full and fair opportunity to litigate.” ¶ 20 (App. 2021) ( ¶ 14 (2019)).

§ 41-619.55(C), (E); ¶ 23 (App. 2021) (a subsequent claim is not precluded when “the statute explicitly invites the offending parent to present evidence of a change in circumstances”).