Cited by

§ 25-319; n.1 (App. 1990).

(the court “may adopt proposed findings that the parties submit” when “those findings are consistent with the ones that it reaches independently after properly considering the facts”).

§ 25- 320(D); n.1 (App. 1990).

(the court “may adopt proposed findings that the parties submit, but only if those findings are consistent with the ones that it reaches independently after properly considering the facts”).

at 241, ¶ 25 (quotation marks omitted) ( (App. 1990)).

Otherwise, there is no assurance that the court itself thought out each issue, and an appellate court cannot effectively review the decision-making process of the trial court.” (quoting Urban Dev.

(holding that a “litigant must object to inadequate findings of fact and conclusions of law at the trial court level so that the court will have an opportunity to correct them.

(noting that "an appellate court may infer that the trial court has made the additional findings necessary to sustain its judgment").

Just as "increased spousal maintenance cannot justify depriving a spouse of his or her property right," Koelsch, 148 Ariz. at 182, decreased spousal maintenance cannot justify an unequal distribution of community debts, ("Property settlements, spousal maintenance awards, and child support awards involve distinct considerations.").

“It must be clear [from the findings] how the court actually did arrive at its conclusions.” (alteration in original) ().

But, where, as here, a party requests findings of fact and conclusions of law, “[i]t must be clear from the findings how the court actually did arrive at its conclusions.” ().

n.1 (App. 1990); see also Ariz. R. Fam.

§ 25–319(A) (2017)1; (explaining that a court “may award spousal maintenance if it finds that any one of four factors is present”).

(finding a parent’s move to Montana was a material change in circumstances even though the court’s minute entry did not specifically find any such change); (“[A]s a general rule, an appellate court may infer that the trial court has made the additional findings necessary to sustain its judgment.”).

§ 25-319(A)(1); (explaining that the superior court may award spousal maintenance if any one of the § 25-319(A) factors is present).

¶19 Moreover, we reject Father’s argument that the court abdicated its “duty to exercise its independent judgment in making findings,” by improperly applying the doctrine of issue preclusion and relying on the juvenile court’s dismissal of the dependency concerning Mother’s older children as evidence that she was not a danger to K.S.

But the court may adopt the findings and conclusions of others so long as they are “consistent with the ones that it reaches independently after properly considering the facts.” (approving the practice of adopting findings proposed by a party after independent analysis) (citations omitted); -74, ¶ 14 (App. 2013) (finding error where the family court “delegated its obligation to independently weigh the evidence” to an expert witness rat

sion of community property under certain circumstances, ¶ 18 (App. 2010), our supreme court has held that “property division and spousal maintenance are two separate and distinct considerations at dissolution,” (-11 (App. 1980)); (“Property settlements, spousal maintenance awards, and child support awards involve distinct considerations.”).

Nonetheless, written findings, including findings of fact, must include “all of the ‘ultimate’ facts—that is, those necessary to resolve the disputed issues.” Ruben M., 230 Ariz. at 242, ¶ 25 ().

Elliott v. Elliott , , 137, , 937 (App. 1990).

(“A litigant must object to inadequate findings of fact and conclusions of law at the trial court level so 3 ALMA M. v. DCS et al. Decision of the Court that the court will have an opportunity to correc

Law P. 82(A); (stating that, when a party submits a timely request for findings of fact, the family court must make findings concerning the ultimate facts).