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Last Post 26 Jun 2026 12:19 PM by  Yolanda Fox
R-26-0009 Petition to Amend Rules 47, 47.1, 47.2, 48 & 91.5, ARFLP
 6 Replies
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Greg Sakall
New Member
Posts:20 New Member

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09 Jan 2026 02:47 PM
    Greg Sakall
    Judge, Division 23
    Pima County Superior Court
    110 W Congress
    Tucson, AZ 85701
    Telephone: (520) 724-8301
    [email protected]

    The Committee on Family Court (“COFC”) respectfully requests that the Court amend Rules 47, 47.1 ,47.2, 48, and 91.5 of the Arizona Rules of Family Law Procedure. The proposed changes address temporary orders and post-judgment enforcement matters regarding legal decision-making and parenting time and are in response to concerns raised by the public and the family court bench.

    Filed: January 9, 2026

    Would amend Rules 47, 47.1, 47.2, 48, and 91.5 of the Rules of Family Law Procedure to modify the rules governing temporary orders and post-judgment enforcement orders affecting legal decision-making and parenting time.

    Comments must be submitted by no later than Friday, May 1, 2026, and any reply by a petitioner must be submitted no later than Monday, June 1, 2026.
    Attachments
    afoster
    New Member
    Posts:48 New Member

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    29 Apr 2026 11:17 PM
    Samuel A. Thumma
    Chair, Arizona Commission on Access to Justice
    Judge, Arizona Court of Appeals
    Division One
    State Courts Building
    1501 West Washington Street
    Phoenix, AZ 85007-3329
    Telephone: (602) 452-6700
    [email protected]
    Attachments
    State Bar of Arizona
    Basic Member
    Posts:214 Basic Member

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    01 May 2026 09:02 PM
    Comment of the State Bar of Arizona

    Jessica J. Fotinos, Bar No. 019777
    General Counsel
    State Bar of Arizona
    4201 N. 24th Street, Suite 100
    Phoenix, AZ 85016-6288
    (602) 340-7236
    [email protected]
    Attachments
    Kandra Durfield
    New Member
    Posts:1 New Member

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    01 May 2026 11:56 PM
    Kandra Durfield
    [email protected]
    308-550-0022

    The proposed requirement in Rule 47(a)(1) that a party “state what happened” with specific acts, dates, and circumstances raises a practical concern in cases involving domestic violence. Given the well-documented effects of trauma, including non-linear and delayed recall, a victim may not be able to fully articulate all relevant incidents at the time of filing a motion for temporary orders.

    As written, the rule does not appear to address whether parties may supplement or amend their allegations prior to the hearing with reasonable notice, or how facts not included in the initial motion may be treated in subsequent proceedings.

    Clarification may be helpful to ensure the rule is not interpreted as requiring an exhaustive recitation at the outset, and that parties retain the ability to supplement or amend filings and present additional relevant evidence related to domestic violence at later stages.
    Yolanda Fox
    Basic Member
    Posts:297 Basic Member

    --
    05 May 2026 05:05 PM
    Amber Snodgrass
    928-910-5625
    1901 W Madison St. #1069
    Phoenix, AZ 85009
    [email protected]

    I respectfully submit this comment in response to the Petition to Amend Rules 47, 47.1, 47.2, 48, and 91.5 of the Arizona Rules of Family Law Procedure.

    I appreciate the Committee on Family Court’s efforts to address longstanding concerns regarding temporary orders, particularly in cases involving allegations of domestic violence and child safety. The proposed amendments reflect a meaningful attempt to improve clarity, efficiency, and procedural consistency.

    However, as currently drafted, certain provisions risk reinforcing existing systemic gaps rather than resolving them, particularly in cases involving domestic violence under A.R.S. § 25-403.03.

    1. Lack of Required Findings in Domestic Violence Cases

    The proposed language allows courts to rule on contested temporary orders without making findings, even where A.R.S. § 25-403.03 is implicated, requiring only that the court “identify which facts it found to be most important.”

    While this may reduce judicial burden, it presents significant legal and practical concerns:
    -It limits meaningful appellate review
    -It obscures whether statutory mandates were properly applied
    -It permits inconsistent application of domestic violence protections

    Domestic violence findings are not discretionary under Arizona law. Where § 25-403.03 is implicated, the statute requires careful analysis of safety risks and the impact on the child.

    Recommendation:
    Require courts to make specific findings as to:
    -Whether domestic violence occurred
    -Whether § 25-403.03 applies
    -How any findings impact parenting time and child safety

    Even at the temporary orders stage, at least minimal relevant findings are essential to ensure accountability and protect children.

    2. Insufficient Safeguards for Meaningful Hearings

    The proposal requires courts to schedule hearings within “reasonable time limits” appropriate to the allegations.

    In practice, this standard is too vague and risks perpetuating one of the very concerns identified in the petition: insufficient time to address domestic violence allegations. Without clearer guidance, hearings involving serious safety concerns may continue to be truncated, preventing full presentation of evidence.

    Recommendation:
    Clarify that courts must ensure sufficient time to meaningfully address domestic violence allegations and defenses. Where necessary, the court should continue the hearing to allow for adequate development of the record.

    3. Overly Restrictive Standard for Review of Temporary Orders

    The proposed mechanism for reviewing temporary orders relies on a showing of “extraordinary circumstances” or imposes a 180-day limitation.

    This standard is overly restrictive given the real-world impact of temporary orders on children and families. Temporary orders often function as de facto final orders, particularly in high-conflict or delayed cases.
    Errors affecting child safety should not require a showing of “extraordinary” circumstances to be reviewed.

    Recommendation:
    Expand the standard for review to include:
    -Material changes in circumstances
    -Newly available evidence
    -Credible safety concerns affecting the child

    4. Continued Reliance on Broad Judicial Discretion

    Throughout the proposed amendments, key provisions use discretionary language such as “may,” “could,” or “should.”

    While flexibility is important, excessive reliance on discretionary language risks inconsistent application across cases, particularly in cases involving domestic violence, where uniformity and adherence to statutory protections are critical.

    Recommendation:
    Where child safety and domestic violence are implicated, consider replacing discretionary language with mandatory language to ensure consistent application of protections.

    5. Need for Explicit Protection of Relevant Evidence

    Although the proposal improves factual specificity in pleadings, it does not address a recurring issue in family court proceedings: the exclusion or limitation of relevant evidence of domestic violence and child safety concerns. Procedural barriers should not prevent courts from considering critical safety evidence.

    Recommendation:
    Include language clarifying that courts should not exclude relevant evidence of domestic violence or child safety concerns where such evidence is necessary to determine the child’s best interests.

    6. Clarification Regarding Scope of Required Allegations

    The proposed language in Rule 47(a)(1) requiring a party to “state what happened,” including specific acts, dates, and circumstances, would benefit from additional clarification and some additional tools.

    As drafted, the rule does not address whether a party may supplement or amend factual allegations after the initial filing, or whether the court may consider relevant facts not included in the motion. This may create uncertainty as to the intended scope of the pleading requirement.

    In cases involving domestic violence, information may not always be fully developed or presented in a complete sequence at the time of filing. Additional details may become available as the matter progresses. A trauma-informed approach to these proceedings recognizes that recall and disclosure may evolve over time.

    In matters implicating A.R.S. § 25-403.03, the court’s ability to consider all relevant information remains central to its determination of the child’s best interests and safety. In appropriate cases, structured risk assessment tools may also assist the court in evaluating potential danger and informing temporary orders.

    Recommendation:
    Clarify that:
    -The pleading requirement is intended to provide sufficient notice, not to limit the scope of evidence
    -Parties may supplement or amend factual allegations as appropriate
    -The court may consider relevant evidence beyond the initial filing when evaluating domestic violence and child safety concerns
    -The rule should be applied in a manner consistent with a trauma-informed approach to the presentation and evaluation of domestic violence allegations
    -Courts should consider the use of validated lethality or risk assessment tools, where appropriate, to inform determinations affecting child and party safety. These are already utilized in other areas of the superior court.

    Conclusion:
    The proposed amendments are a meaningful step toward improving family court procedures. However, without stronger safeguards, they risk maintaining the very issues they seek to address, particularly in cases involving domestic violence and child safety.

    By incorporating targeted revisions to require findings, ensure meaningful hearings, broaden review standards, and protect the consideration of relevant evidence, the Court can significantly strengthen both the fairness and safety of temporary orders proceedings.

    Thank you for the opportunity to provide comment and for your continued efforts to improve Arizona’s family court system.

    Respectfully submitted,

    Amber Snodgrass
    Greg Sakall
    New Member
    Posts:20 New Member

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    19 May 2026 01:04 PM
    Please find attached COFC's Reply in support of the Petition.

    Greg Sakall
    Judge, Division 23
    Pima County Superior Court
    110 W Congress
    Tucson, AZ 85701
    Telephone: (520) 724-8301
    [email protected] (for COFC purposes only)
    Attachments
    Yolanda Fox
    Basic Member
    Posts:297 Basic Member

    --
    26 Jun 2026 12:19 PM
    Greg Sakall
    Judge, Division 23
    Pima County Superior Court
    110 W Congress
    Tucson, AZ 85701
    Telephone: (520) 724-8301
    [email protected]

    SUPPLEMENT TO REPLY IN SUPPORT OF PETITION
    Attachments
    Topic is locked