Ariz. Rev. Stat. » Title 14
Arizona Revised Statutes

Ariz. Rev. Stat. § 14-10415 (2026)

Reformation to correct mistakes

✓ text as last checked Oct. 2026 (this copy records no edition or section history)
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14-10415. Reformation to correct mistakes

The court may reform the terms of a trust, even if unambiguous, to conform the terms to the settlor's intention if it is proved by clear and convincing evidence that both the settlor's intent and the terms of the trust were affected by a mistake of fact or law, whether in expression or inducement.

 

Notes of Decisions
Cited in 4 cases (2 in the last 5 years), 2016–2026 · leading case: Hogan v. O'hara, No. 1 CA-CV 15-0059 (Ariz. Ct. App. June 21, 2016).
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Hogan v. O'hara, No. 1 CA-CV 15-0059 (Ariz. Ct. App. June 21, 2016). · cites it 11× “¶14 Pursuant to A.R.S. § 14-10415: The court may reform the terms of a trust, even if unambiguous, to conform the terms to the settlor's intention if it is proved by clear and convincing evidence that both the settlor's intent and the terms of the trust were affected by a…”
Taylor v. Credille, No. 1 CA-CV 17-0690 (Ariz. Ct. App. Sept. 27, 2018). · cites it 2× “Doug answered the amended petition, counterclaiming again for similar relief, but this time seeking reformation of the Trust pursuant to A.R.S. § 14-10415 (2018). ¶6 Pamala and Darrel then moved for summary judgment, which the superior court granted, over Doug's opposition.”
Donovan v. Donovan, No. 1 CA-CV 25-0397 PB (Ariz. Ct. App. Mar. 20, 2026). · cites it 2× “§ 14-10415, which permits reformation of a trust, even in cases of unambiguity, to conform to a settlor’s intent if proved by clear and convincing evidence that a mistake affected the intent and the trust’s terms. Unlike wills, trusts do not necessarily need to be signed.”
Karen Bass v. George Michael Bogle, No. 03-23-00319-CV, 2024 WL 3446921 (Tex. App.—Austin July 18, 2024). “054 (authorizing reformation of trust); see also Ariz. Rev. Stat. § 14-10415 (authorizing court to reform terms of trust to correct mistakes).”
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