Arizona Revised Statutes

Ariz. Rev. Stat. § 25-1032 (2026)

Exclusive continuing jurisdiction

✓ current as of May 2026
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25-1032. Exclusive continuing jurisdiction

A. Except as otherwise provided in section 25-1034, a court of this state that has made a child custody determination consistent with section 25-1031 or 25-1033 has exclusive, continuing jurisdiction over the determination until either of the following is true:

1. A court of this state determines that neither the child, nor the child and one parent, nor the child and a person acting as a parent have a significant connection with this state and that substantial evidence is no longer available in this state concerning the child's care, protection, training and personal relationships.

2. A court of this state or a court of another state determines that the child, the child's parents and any person acting as a parent do not presently reside in this state.

B. A court of this state that has made a child custody determination and does not have exclusive, continuing jurisdiction under this section may modify that determination only if it has jurisdiction to make an initial determination under section 25-1031.  

 

Notes of Decisions
Cited in 30 cases (11 in the last 5 years), 2002–2026 · leading case: Mangan v. Mangan, 258 P.3d 164 (Ariz. Ct. App. 2011).
Mangan v. Mangan, 258 P.3d 164 (Ariz. Ct. App. 2011). · cites it 9× “Except as [inapplicable here], a court of this State that has made a child custody determination consistent with § 25-1031 .”
Frank R. v. Mother Goose Adoptions, 367 P.3d 88 (Ariz. Ct. App. 2016). · cites it 8× “, retained strong connections to Arizona, see § 25-1032. The court set the motion for hearing on October 8.”
Angel B. v. Vanessa J., 316 P.3d 1257 (Ariz. Ct. App. 2014). · cites it 9× “See AR.S. §§ 25-1032 to -33, -1063 (“A court of this state shall afford full faith and credit to an order that is issued by another state, that is consistent with” the UCCJEA); Melgar, 215 Ariz.”
Melgar v. Campo, 161 P.3d 1269 (Ariz. Ct. App. 2007). · cites it 7× “Specifically, A.R.S. § 25-1032 5 reflects the UCCJEA goal of allowing the court that makes the original custody determination to retain exclusive, continuing jurisdiction over that order.”
Gutierrez v. Hon. fox/kivlighn, 394 P.3d 1096 (Ariz. Ct. App. 2017). · cites it 2× “For a child under the age of six months, “home state” is “the state in which the child lived from birth with a parent or person acting as a parent, including any period during which that person is temporarily absent from that state.” A.R.S. § 25-1002(7)(b) (emphasis added).”
Welch-Doden v. Roberts, 42 P.3d 1166 (Ariz. Ct. App. 2002). · cites it 2× “A.R.S. § 25-1032. The Relevant Statutes and the Statutory Conflict ¶ 15 Section 25-1031 is the statutory starting place for determining initial jurisdiction.”
Berrier v. Rountree, 433 P.3d 8 (Ariz. Ct. App. 2018). “To the contrary, § 25-408(C), without restriction, authorizes "a parent who is seeking to relocate the child [to petition] the court for a hearing, on notice to the other parent, to determine the appropriateness of a relocation that may adversely affect the other parent's legal…”
Monique B./donald B. v. Hon duncan/dcs, 429 P.3d 1165 (Ariz. Ct. App. 2018). · cites it 8× “See A.R.S. § 25-1032; accord Ala. Code § 30 -3B-202.”
Morgan v. Morgan (Ariz. Ct. App. 2025). · cites it 12× “¶13 Mother next argues the superior court did not have exclusive, continuing jurisdiction under A.R.S. § 25-1032 because it adopted the parties’ stipulation that they were residing outside of Arizona at the time of the modification.”
Lincoln v. McDaniel (Ariz. Ct. App. 2026). · cites it 10× “Exclusive, continuing jurisdiction ¶12 Mother next argues that the court should have transferred jurisdiction to Georgia because Arizona no longer had exclusive, continuing jurisdiction under A.R.S. § 25-1032. We review the superior court’s UCCJEA jurisdiction de novo.”
Tillman v. Smith (Ariz. Ct. App. 2025). · cites it 8× “See A.R.S. §§ 25-1032(A), -1037. The court, in a minute entry entered later in September, stated it would treat Mother’s filing as a motion to dismiss.”
Whitman v. Whitman (Ariz. Ct. App. 2019). · cites it 5× “A.R.S. § 25-1032(A). The superior court did not make either of these findings, nor did Mother ask it to.”
— Ariz. Rev. Stat. § 25-1032(A) — 17 cases
Gutierrez v. Hon. fox/kivlighn, 394 P.3d 1096 (Ariz. Ct. App. 2017). “For a child under the age of six months, “home state” is “the state in which the child lived from birth with a parent or person acting as a parent, including any period during which that person is temporarily absent from that state.” A.R.S. § 25-1002(7)(b) (emphasis added).”
Melgar v. Campo, 161 P.3d 1269 (Ariz. Ct. App. 2007). “Specifically, A.R.S. § 25-1032 5 reflects the UCCJEA goal of allowing the court that makes the original custody determination to retain exclusive, continuing jurisdiction over that order.”
Angel B. v. Vanessa J., 316 P.3d 1257 (Ariz. Ct. App. 2014). “See AR.S. §§ 25-1032 to -33, -1063 (“A court of this state shall afford full faith and credit to an order that is issued by another state, that is consistent with” the UCCJEA); Melgar, 215 Ariz.”
Berrier v. Rountree, 433 P.3d 8 (Ariz. Ct. App. 2018). “To the contrary, § 25-408(C), without restriction, authorizes "a parent who is seeking to relocate the child [to petition] the court for a hearing, on notice to the other parent, to determine the appropriateness of a relocation that may adversely affect the other parent's legal…”
Monique B./donald B. v. Hon duncan/dcs, 429 P.3d 1165 (Ariz. Ct. App. 2018). “See A.R.S. § 25-1032; accord Ala. Code § 30 -3B-202.”
— Ariz. Rev. Stat. § 25-1032(A)(1) — 3 cases
Lincoln v. McDaniel (Ariz. Ct. App. 2026). “Exclusive, continuing jurisdiction ¶12 Mother next argues that the court should have transferred jurisdiction to Georgia because Arizona no longer had exclusive, continuing jurisdiction under A.R.S. § 25-1032. We review the superior court’s UCCJEA jurisdiction de novo.”
Torrez v. Bombard (Ariz. Ct. App. 2018).
Srery v. Hon hinz/srery (Ariz. Ct. App. 2017).
— Ariz. Rev. Stat. § 25-1032(A)(2) — 4 cases
Frank R. v. Mother Goose Adoptions, 367 P.3d 88 (Ariz. Ct. App. 2016). “, retained strong connections to Arizona, see § 25-1032. The court set the motion for hearing on October 8.”
Morgan v. Morgan (Ariz. Ct. App. 2025). “¶13 Mother next argues the superior court did not have exclusive, continuing jurisdiction under A.R.S. § 25-1032 because it adopted the parties’ stipulation that they were residing outside of Arizona at the time of the modification.”
Lincoln v. McDaniel (Ariz. Ct. App. 2026). “Exclusive, continuing jurisdiction ¶12 Mother next argues that the court should have transferred jurisdiction to Georgia because Arizona no longer had exclusive, continuing jurisdiction under A.R.S. § 25-1032. We review the superior court’s UCCJEA jurisdiction de novo.”
— Ariz. Rev. Stat. § 25-1032(B) — 1 case
In Re the Marriage of Morris & Mandel, 529 P.3d 94 (Ariz. Ct. App. 2023).
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