Cited by

The superior court has the “sound discretion” to decide whether changed circumstances warrant a modification, (), and the “Guidelines do not replace the exercise of trial discretion; they focus it.” Id.

(failure to rule on fee request); (failure to rule on motion to strike presentence report).

¶21 We interpret the Guidelines de novo, ¶ 7 (App. 2017), but will affirm the court’s findings regarding Father’s income if they are supported by sufficient evidence and not clearly erroneous

particularly when such income is controlled by the party [her]self and is subject to possible manipulation.”

where we held a party who had agreed to proceed “by avowal” could not later challenge the sufficiency of the evidence on appeal.

(court may deviate from the guidelines if “application of the guidelines is inappropriate or unjust in a particular case” and deviation is in the best interests of the child.)

(explaining the failure to rule on a motion constitutes an implicit denial of the motion).

(failure to rule on a motion is implicit denial of the motion).

The superior court retains “the sound discretion” to determine “whether changed circumstances exist to warrant modification of an award,” , and the “Guidelines do not replace the exercise of trial court discretion; they focus it.” Id.

Franco argues that “[c]hild support amounts should be set according to a payor’s current income,” citing in support this court’s

(holding that a court’s failure to rule on motions for attorneys’ fees implies that the motions were denied).

-37, -97 (App. 1997) (“‘[T]he focus [is] on the parties’ relative abilities to pay the fees incurred’ in accord with .

(decision on attorney fees “lies within the trial court’s sound discretion, ‘with the focus on the parties’ relative abilities to pay the fees incurred’ ”), -95 , -90 (App. 1995).

See Pearson v. Pearson, 190 Ariz. 231, 236, (decision on attorney fees “lies within the trial court‟s sound discretion, „with the focus on the parties‟ relative abilities to pay the fees incurred‟”), -95, -90 (App. 1995).

[and][t]he statute is designed to ensure that the poorer party has the proper means to litigate the action.” , we upheld the trial court’s denial of fees, noting that such a decision must “focus on the parties’ relative abilities to pay the fees incurred....” , we performed a comparative examination of the parties’ reso