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“Due process errors require reversal only if a party is thereby prejudiced.” ¶ 26 (App. 2014).

¶20 This does not conclude our review, as “[d]ue process errors require reversal only if a party is thereby prejudiced.” ¶ 26 (App. 2014).

In such a case, the court must hold a hearing.”); –68, ¶¶ 14, 18, 21 (App. 2014) (recognizing that documentary evidence is inadequate to permit reliable assessment of credibility, and holding that the court violates due process by disallowing meaningful direct testimony and adequate cross-examination when resolution of material contested issue hinges on credibili

¶ 20 (App. 2014) (citation omitted); see also Heidbreder v. 3 ¶ 14 (App. 2012) (“A trial court errs if it modifies child support without .

¶ 1 (App. 2014); see also Solorzano v. Jensen, --- Ariz. ---, ---, 2020 WL 7703115, at *3, ¶ 13 (App. Dec.

¶ 26 (App. 2014) (holding a due process violation must be prejudicial to warrant reversal).

¶ 26 (App. 2014) (“Due process errors require reversal only if a party is thereby prejudiced.”).

¶ 16 4 The court certified the decree as final under Arizona Rule of Family Law Procedure (“Rule”) 78(b) and (c).

Thus, this court has held that “[t]hough the court may impose time limits that appear reasonable in advance of a proceeding, those limits become unreasonable if they prove insufficient to allow a substantive hearing.” ¶ 21 (App. 2014).

The court is not required to “indulge inefficient use of time by parties or their counsel.” ¶ 22 (App. 2014).

- 69, ¶¶ 19, 24 (App. 2014).

¶25 The court is not required to “indulge inefficient use of time by parties or their counsel.” ¶ 22 (App. 2014).

¶8 Due process requires that the court “afford the parties ‘an opportunity to be heard at a meaningful time and in a meaningful manner.’” ¶ 20 (App. 2014) (citation omitted).

at 102, ¶ 18; see also Rule 44(G) (2018); ¶ 7 (App. 2017) (the court is to grant legal decision-making consistent with the best interests of the child even if the party has not petitioned for such relief); – 69, ¶¶ 15–18, 23–24 (App. 2014) (it is a violation of the basic principle of due process to resolve contested facts absent two critical checks of our adversarial system: sworn in-person testimony subjected to cross- 4 ZANDELL v. ZANDELL

requires an assessment of credibility, the court must afford the parties an opportunity to present sworn oral testimony, and may not rely solely on avowals of counsel.” ¶ 1.

¶ 20 (App. 2014) ( ¶ 16 (App. 2006)); see also Ariz. R. Fam.

Though Husband argues that Wife prematurely filed her request for a status conference and that the court was not required to hold a conference, due process requires the court, when factual disputes exist, to “afford the parties an opportunity to present sworn oral testimony, and [ ] not rely solely on avowals of counsel.” ¶ 1 (App. 2014).

¶16 The superior court “enjoys broad discretion to ‘impose reasonable time limits on all proceedings or portions thereof and [to] limit the time to scheduled time.’” ¶ 20 (App. 5 The DCS records show that these records were delivered on September 6, 2017, which would indicate an October deadline for disclosure.

earlier finding of waiver remains effective as to the portions of the hearing during which the parent was absent, and the court need not start the hearing 5 “Though Father did not object with the magic words of due process, he implicitly raised the same arguments below that he now presents on [appeal] and therefore adequately preserved the issue for our review.” n.6, ¶ 22 (App. 2014) (internal quotation omitted).

The family court has broad discretion to “impose reasonable time limits on all proceedings or portions thereof and [to] limit the time to scheduled time.” ¶ 20 (App. 2014).

¶ 20 (App. 2014); see also Ariz. R. Fam.

Law P. 77(B)(1); ¶ 20 (App. 2014).

“The determination of when additional time is necessary is normally committed to the discretion of the trial court.” ¶ 22 (App. 2014).