Background
Audrey Hancock and Brandon Hancock divorced in 2022 and initially shared joint legal decision-making for their three minor children. In January 2025, Mother sought sole legal decision-making and supervised parenting time for Father, alleging psychological abuse. Father countered with a petition concerning contempt, enforcement of parenting time, and legal-decision-making authority.
Before the August 2025 evidentiary hearing, Mother disclosed proposed exhibits late. The superior court excluded the exhibits but allowed her to testify about their contents. It awarded Father sole legal decision-making, imposed parenting plans for two children while allowing a third to choose her schedule, found Mother in contempt, and ordered Mother to pay $570 monthly child support.
The Court’s Holding
The Court of Appeals affirmed the legal-decision-making and parenting-time rulings. It held that the superior court did not abuse its discretion by excluding Mother’s untimely disclosed exhibits, denying her request to interview the children, or declining to expand the one-hour hearing. The record supported the court’s finding that Father was prejudiced by the late disclosures, and Mother had not included the excluded exhibits or an offer of proof in the appellate record.
The court also held that the superior court properly used the two-worksheet method under the Arizona Child Support Guidelines because Father had more than half of the parenting time with two children and Mother had more than half with the third. But the appellate court could not determine how the worksheet figures produced the $570 monthly obligation. It therefore vacated the child-support order and remanded for recalculation using two worksheets and supporting findings.
Key Takeaways
- Late disclosure may justify excluding evidence when the opposing party lacks time to review or authenticate it.
- A court may consider children’s wishes through parental testimony; an in-camera interview is discretionary.
- A child-support order must explain how worksheet calculations lead to the final support amount.
Why It Matters
The decision underscores that family-court sanctions cannot prevent consideration of material best-interests evidence, but an appellant must preserve excluded evidence for appellate review. It also requires transparent child-support calculations when different children have different parenting-time arrangements.