Arizona Revised Statutes

Ariz. Rev. Stat. § 25-403.02 (2026)

Parenting plans

✓ current as of May 2026

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25-403.02. Parenting plans

A. If the child's parents cannot agree on a plan for legal decision-making or parenting time, each parent must submit a proposed parenting plan.

B. Consistent with the child's best interests in section 25-403 and sections 25-403.03, 25-403.04 and 25-403.05, the court shall adopt a parenting plan that provides for both parents to share legal decision-making regarding their child and that maximizes their respective parenting time. The court shall not prefer a parent's proposed plan because of the parent's or child's gender.

C. Parenting plans shall include at least the following:

1. A designation of the legal decision-making as joint or sole as defined in section 25-401.

2. A description of each parent's rights and responsibilities for the personal care of the child and for decisions in areas such as education, health care and religious training.

3. A practical schedule of parenting time for the child, including holidays and school vacations.

4. A procedure for the exchanges of the child, including location and responsibility for transportation. The parenting plan must specify when the exchange is required to take place at a safe exchange location pursuant to section 25-403.10.

5. A procedure by which proposed changes, relocation of where a child resides with either parent pursuant to section 25-408, disputes and alleged breaches may be mediated or resolved, which may include the use of conciliation services or private counseling.

6. A procedure for periodic review of the plan's terms by the parents.

7. A procedure for parents to communicate with each other about the child, including methods and frequency.

8. A statement that each party has read, understands and will abide by the notification requirements of section 25-403.05, subsection B.

D. If the parents are unable to agree on any element to be included in a parenting plan, the court shall determine that element. The court may determine other factors that are necessary to promote and protect the emotional and physical health of the child.

E. Shared legal decision-making does not necessarily mean equal parenting time.

Notes of Decisions

Cited in 59 cases (35 in the last 5 years), 2009–2026 · leading case: Paul E. v. Courtney F., 439 P.3d 1169 (Ariz. 2019).

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Paul E. v. Courtney F., 439 P.3d 1169 (Ariz. 2019). · cites it 6× “See A.R.S. § 25-403.02(C)(2) (permitting a parenting plan to address any issue and requiring a description of "[e]ach parent's rights and responsibilities for the personal care of the child and for decisions in areas such as education, health care and religious training").”

Ball v. Ball, 478 P.3d 704 (Ariz. Ct. App. 2020). · cites it 10× “¶6 In Arizona, joint legal decision-making arrangements must address each parent’s “rights and responsibilities” for the child’s care and decisions regarding education, health care, and religious training.”

Jordan v. Rea, 212 P.3d 919 (Ariz. Ct. App. 2009). · cites it 6× “A.R.S. § 25-403.02(A). The parenting-plan must include “each parent’s rights and responsibilities .”

Baker v. Meyer, 346 P.3d 998 (Ariz. Ct. App. 2015). · cites it 5× “A.R.S. § 25-403.02(0(1), (2). The plan also must contain “[a] practical schedule of parenting time for the child, including holidays and school vacations.”

Mesa v. O'Connor, 563 P.3d 1179 (Ariz. Ct. App. 2025). · cites it 8× “¶20 Father also argues the court failed to create a parenting schedule that maximized his parenting time or that gave a practical schedule for holidays and school vacations, violating A.R.S. § 25-403.02. See A.R.S. § 25-403.02(B) (“[T]he court shall adopt a parenting plan that .”

Barron v. Barron, 443 P.3d 977 (Ariz. Ct. App. 2018). · cites it 2× “02(B) (2018) requires the superior court to adopt a parenting plan that is "[c]onsistent with the child's best interests in § 25-403" and that "maximizes [each parent's] respective parenting time." Section 25-403 (A) (2018) requires the court to determine parenting time "in…”

Nicaise v. Sundaram, 418 P.3d 1045 (Ariz. Ct. App. 2018). · cites it 3× “Section 25-403.02 defines the required elements of a parenting plan, and none relate to the authorization of particular substantive decisions.”

Lisa Friedman v. David C Roels Jr, 418 P.3d 884 (Ariz. 2018). “When Mother and Father presented the Parenting Plan to the family court for approval, Father, without objection from Mother, stated that the parties had "not made an agreement on ... whether or not his parents can be present at his parenting time.”

Paul E. v. Courtney F., 418 P.3d 413 (Ariz. Ct. App. 2018). · cites it 2× “" 'Joint legal decision-making' means both parents share decision-making and neither parent's rights or responsibilities are superior," and " '[s]ole legal decision-making' means one parent has the legal right and responsibility to make major decisions for a child.”

Kaye v. Kaye (Ariz. Ct. App. 2017). · cites it 20× “§ 25-403(A) (enumerating best interests factors court is required to consider in addition to all relevant factors in determining whether parenting time is in best interests of child); see also A.R.S. § 25-403.02(B) (court shall adopt parenting plan consistent with child’s best…”

Windschill v. Windschill (Ariz. Ct. App. 2023). · cites it 16× “2019) (applying A.R.S. § 25-403.02 in context of relocation).”

Bennie v. Johnson (Ariz. Ct. App. 2022). · cites it 14× “The court likely meant to cite Subsection B of A.R.S. § 25-403.02. See A.R.S. § 25-403.02(B) (“Consistent with the child’s best interests .”

Show all 59 citing cases →

— Ariz. Rev. Stat. § 25-403.02(A) — 4 cases

Jordan v. Rea, 212 P.3d 919 (Ariz. Ct. App. 2009). “A.R.S. § 25-403.02(A). The parenting-plan must include “each parent’s rights and responsibilities .”

Robles v. Palencia (Ariz. Ct. App. 2017).

Davis v. Landon (Ariz. Ct. App. 2019).

Ortega v. Robles (Ariz. Ct. App. 2025).

— Ariz. Rev. Stat. § 25-403.02(A)(1) — 1 case

Jordan v. Rea, 212 P.3d 919 (Ariz. Ct. App. 2009). “A.R.S. § 25-403.02(A). The parenting-plan must include “each parent’s rights and responsibilities .”

— Ariz. Rev. Stat. § 25-403.02(B) — 34 cases

Jordan v. Rea, 212 P.3d 919 (Ariz. Ct. App. 2009). “A.R.S. § 25-403.02(A). The parenting-plan must include “each parent’s rights and responsibilities .”

Barron v. Barron, 443 P.3d 977 (Ariz. Ct. App. 2018). “02(B) (2018) requires the superior court to adopt a parenting plan that is "[c]onsistent with the child's best interests in § 25-403" and that "maximizes [each parent's] respective parenting time." Section 25-403 (A) (2018) requires the court to determine parenting time "in…”

Ball v. Ball, 478 P.3d 704 (Ariz. Ct. App. 2020). “¶6 In Arizona, joint legal decision-making arrangements must address each parent’s “rights and responsibilities” for the child’s care and decisions regarding education, health care, and religious training.”

Baker v. Meyer, 346 P.3d 998 (Ariz. Ct. App. 2015). “A.R.S. § 25-403.02(0(1), (2). The plan also must contain “[a] practical schedule of parenting time for the child, including holidays and school vacations.”

Mesa v. O'Connor, 563 P.3d 1179 (Ariz. Ct. App. 2025). “¶20 Father also argues the court failed to create a parenting schedule that maximized his parenting time or that gave a practical schedule for holidays and school vacations, violating A.R.S. § 25-403.02. See A.R.S. § 25-403.02(B) (“[T]he court shall adopt a parenting plan that .”

— Ariz. Rev. Stat. § 25-403.02(C) — 5 cases

Kaye v. Kaye (Ariz. Ct. App. 2017). “§ 25-403(A) (enumerating best interests factors court is required to consider in addition to all relevant factors in determining whether parenting time is in best interests of child); see also A.R.S. § 25-403.02(B) (court shall adopt parenting plan consistent with child’s best…”

Flores v. Florian (Ariz. Ct. App. 2026).

Zimmerman v. Zimmerman (Ariz. Ct. App. 2015).

Price v. Price (Ariz. Ct. App. 2017).

Bennie v. Johnson (Ariz. Ct. App. 2022). “The court likely meant to cite Subsection B of A.R.S. § 25-403.02. See A.R.S. § 25-403.02(B) (“Consistent with the child’s best interests .”

— Ariz. Rev. Stat. § 25-403.02(C)(1) — 2 cases

Paul E. v. Courtney F., 418 P.3d 413 (Ariz. Ct. App. 2018). “" 'Joint legal decision-making' means both parents share decision-making and neither parent's rights or responsibilities are superior," and " '[s]ole legal decision-making' means one parent has the legal right and responsibility to make major decisions for a child.”

— Ariz. Rev. Stat. § 25-403.02(C)(2) — 3 cases

Paul E. v. Courtney F., 439 P.3d 1169 (Ariz. 2019). “See A.R.S. § 25-403.02(C)(2) (permitting a parenting plan to address any issue and requiring a description of "[e]ach parent's rights and responsibilities for the personal care of the child and for decisions in areas such as education, health care and religious training").”

Morales v. Morales (Ariz. Ct. App. 2025).

— Ariz. Rev. Stat. § 25-403.02(C)(3) — 9 cases

Riordan v. Kangas (Ariz. Ct. App. 2026).

Robles v. Palencia (Ariz. Ct. App. 2017).

McGuire-lally v. Lally (Ariz. Ct. App. 2021).

— Ariz. Rev. Stat. § 25-403.02(C)(4) — 1 case

Schritter v. Schritter (Ariz. Ct. App. 2024).

— Ariz. Rev. Stat. § 25-403.02(C)(6) — 1 case

Bennie v. Johnson (Ariz. Ct. App. 2022). “The court likely meant to cite Subsection B of A.R.S. § 25-403.02. See A.R.S. § 25-403.02(B) (“Consistent with the child’s best interests .”

— Ariz. Rev. Stat. § 25-403.02(C)(7) — 1 case

Mindiola v. Mindiola (Ariz. Ct. App. 2021).

— Ariz. Rev. Stat. § 25-403.02(D) — 13 cases

Nicaise v. Sundaram, 418 P.3d 1045 (Ariz. Ct. App. 2018). “Section 25-403.02 defines the required elements of a parenting plan, and none relate to the authorization of particular substantive decisions.”

McCall v. Drury (Ariz. Ct. App. 2016).

— Ariz. Rev. Stat. § 25-403.02(E) — 5 cases

Bennie v. Johnson (Ariz. Ct. App. 2022). “The court likely meant to cite Subsection B of A.R.S. § 25-403.02. See A.R.S. § 25-403.02(B) (“Consistent with the child’s best interests .”

Deguzman v. Deguzman (Ariz. Ct. App. 2024).

Tillman v. Smith (Ariz. Ct. App. 2025).

Sidoti v. Sidoti (Ariz. Ct. App. 2019).

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