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

Ariz. Rev. Stat. § 14-10415 (2026)

Reformation to correct mistakes

✓ current as of May 2026
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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 (Ariz. Ct. App. 2016).
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Hogan v. O'hara (Ariz. Ct. App. 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 (Ariz. Ct. App. 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 (Ariz. Ct. App. 2026). · cites it 2× “¶17 We are not persuaded by Appellants’ argument that following the “modern rule” to reform wills would align with Arizona’s enactment of A.R.S. § 14-10415, which permits reformation of a trust, even in cases of unambiguity, to conform to a settlor’s intent if proved by clear…”
Karen Bass & Lynn Smith, in Their Capacity as Successor Co-Trs. on Behalf of the Amended & Restated George E. Bogle & Nancy T. Bogle Jt. Revocable Trust, Dated March 2, 2021 v. George Michael Bogle & Katherine Leigh Bogle Leavitt (Tex. App. 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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