Background
Adlene Joseph and Nikola Obradovic married in 2020 and have one minor child. After Joseph petitioned for dissolution in March 2024, the parties resolved some financial matters through an Arizona Rule of Family Law Procedure 69 agreement and tried the remaining issues in June 2025.
The superior court awarded Obradovic $1,900 per month in spousal maintenance for 24 months and ordered Joseph to make a $37,251.60 property-equalization payment. In resolving post-trial motions, the court corrected its child-support calculation and ordered Joseph to pay Obradovic $109 per month. It also corrected a clerical error stating that maintenance would last 24 years rather than 24 months. Joseph appealed the maintenance and child-support rulings.
The Court’s Holding
The Court of Appeals affirmed the spousal-maintenance award. Reasonable evidence supported the finding that Obradovic lacked sufficient property to meet his reasonable needs, even considering the equalization payment. Because that ground independently established eligibility under A.R.S. § 25-319(A)(1), the court did not address the alternative finding that he lacked adequate earning ability to be self-sufficient.
The court also upheld the amount and duration of maintenance. The superior court acted within its discretion by treating only Obradovic’s higher-paying full-time job—$90,000 annually—as actual income because he began the second job after separation to cover living expenses and debt, rather than as income regularly earned by the marital community. The 24-month award fell within the applicable guideline range. Correcting “24 years” to “24 months” after September 1, 2025, was a clerical correction, not a modification requiring use of the 2025 Spousal Maintenance Guidelines.
The child-support award was also affirmed. Arizona’s Child Support Guidelines generally do not require inclusion of income beyond full-time employment, so the superior court could exclude Obradovic’s second full-time job. Because the maintenance award stood, it supplied no basis for recalculating child support.
Key Takeaways
- A spouse may qualify for maintenance despite receiving an equalization payment when the record shows the apportioned property remains insufficient to meet reasonable needs.
- Income from a second full-time job begun after separation to meet expenses need not be treated as income regularly earned by the marital community for maintenance purposes.
- Correcting an order from 24 years of maintenance to 24 months was a clerical correction, not a modification triggering newer guidelines.
- For child support, a court generally need not count income earned beyond full-time employment.
Why It Matters
The memorandum decision illustrates the discretion Arizona family courts retain when deciding whether additional employment income should affect maintenance and child support. The circumstances and timing of a second job may matter more than the mere fact that the income was being earned at trial.
It also distinguishes a clerical correction from a substantive modification of maintenance. Because the decision is designated nonprecedential under Arizona Supreme Court Rule 111(c), its use as authority is limited.