Ariz. Rev. Stat. » Title 25
Arizona Revised Statutes

Ariz. Rev. Stat. § 25-403.09 (2026)

Child support

✓ text as last checked Oct. 2026 (this copy records no edition or section history)
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25-403.09. Child support

A. For any parenting time order entered under this article, the court shall determine an amount of child support in accordance with section 25-320 and guidelines established pursuant to that section.

B. An award of joint legal decision-making or a substantially equal parenting time plan does not diminish the responsibility of either parent to provide for the support of the child.

 

Notes of Decisions
Cited in 11 cases (6 in the last 5 years), 2012–2025 · leading case: Heidbreder v. Heidbreder, 284 P.3d 888 (Ariz. Ct. App. 2012).
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Heidbreder v. Heidbreder, 284 P.3d 888 (Ariz. Ct. App. 2012). · cites it 25× “§ 25-327(A) (stating that provisions of a decree regarding child support may be modified upon a “showing of changed circumstances that are substantial and continuing.”
Woolwine v. Abdallah, No. 1 CA-CV 24-0775-FC (Ariz. Ct. App. May 20, 2025). · cites it 6× “§ 25-320, Arizona Child Support Guidelines (“Guidelines”) § 1(D) (“The court must consider child support in any action to establish or modify legal decision-making, parenting time, and child support or past support, whether temporary or final, and whether intrastate or…”
Kittel v. Kittel, No. 1 CA-CV 15-0073-FC (Ariz. Ct. App. Feb. 9, 2016). · cites it 5× “See A.R.S. § 25-403.09 (Supp. 2015); Heidbreder v.”
Schritter v. Schritter, No. 1 CA-CV 23-0550-FC (Ariz. Ct. App. Oct. 1, 2024). · cites it 4× “9 ¶35 Even so, the superior court erred by using Mother’s reduced parenting time to calculate the modified support order when the matter was being litigated.”
Bastian v. Endresen, No. 1 CA-CV 14-0038-FC (Ariz. Ct. App. Dec. 3, 2015). · cites it 6× “Pursuant to A.R.S. § 25-403.09(A), “the court shall determine an amount of child support in accordance with § 25-320 and guidelines” when entering “any parenting time order[.”
In re the Support of V.L., 558 P.3d 962 (Ariz. Ct. App. 2024). · cites it 3× “Further, despite its language that child support was “a non-issue,” the 2017 order does not clearly indicate that the court intended to leave child support unresolved rather than determining that the appropriate amount of child support at that time was zero. If the court’s order…”
Walker v. Guy, No. 1 CA-CV 20-0170-FC (Ariz. Ct. App. Oct. 29, 2020). · cites it 2× “¶26 The superior court reduced Mother’s parenting time by more than fifty percent and concluded the parties’ current incomes constituted a sufficient change in circumstances to justify modifying the child support.”
Johnson v. Johnson, No. 1 CA-CV 20-0175-FC (Ariz. Ct. App. Jan. 7, 2021). · cites it 2× “And Father had “adequate notice and a meaningful opportunity to be heard” on child support issues. Id. at 381, ¶ 13 . Indeed, Father himself petitioned the court to modify the child support order so that Mother paid support to Father.”
Perez v. Richardson, No. 1 CA-CV 21-0041-FC (Ariz. Ct. App. Dec. 7, 2021). · cites it 2× “Guideline 26(B)(3) provides: Benefits, such as Social Security Disability or Insurance, received by a parent on behalf of a child, as a result of contributions made by the other parent who is ordered to pay child support shall be credited . . . If the amount of the child’s…”
Atkison v. Shafer, No. 1 CA-CV 22-0004-FC (Ariz. Ct. App. Dec. 29, 2022). · cites it 2× “If the court intended to deviate from the guidelines to enter a zero-child-support award, it must state the reasons on the record.”
Dominick J. Leonardo v. Ashli Leonardo - Concur/Dissent, No. M2014-00372-COA-R3-CV, 2015 WL 3852802 (Tenn. Ct. App. June 18, 2015). · cites it 2× “at 891 (citing Ariz. Rev. Stat. Ann. § 25-403.09 (A)). Thus, the Arizona Court of Appeals concluded that “once the court granted [m]other‟s petition to modify custody, it was required to address child support.”
Ariz. Rev. Stat. § 25-403.09(A): 7 cases
Heidbreder v. Heidbreder, 284 P.3d 888 (Ariz. Ct. App. 2012). “§ 25-327(A) (stating that provisions of a decree regarding child support may be modified upon a “showing of changed circumstances that are substantial and continuing.”
Schritter v. Schritter, No. 1 CA-CV 23-0550-FC (Ariz. Ct. App. Oct. 1, 2024). “9 ¶35 Even so, the superior court erred by using Mother’s reduced parenting time to calculate the modified support order when the matter was being litigated.”
Woolwine v. Abdallah, No. 1 CA-CV 24-0775-FC (Ariz. Ct. App. May 20, 2025). “§ 25-320, Arizona Child Support Guidelines (“Guidelines”) § 1(D) (“The court must consider child support in any action to establish or modify legal decision-making, parenting time, and child support or past support, whether temporary or final, and whether intrastate or…”
Bastian v. Endresen, No. 1 CA-CV 14-0038-FC (Ariz. Ct. App. Dec. 3, 2015). “Pursuant to A.R.S. § 25-403.09(A), “the court shall determine an amount of child support in accordance with § 25-320 and guidelines” when entering “any parenting time order[.”
In re the Support of V.L., 558 P.3d 962 (Ariz. Ct. App. 2024). “Further, despite its language that child support was “a non-issue,” the 2017 order does not clearly indicate that the court intended to leave child support unresolved rather than determining that the appropriate amount of child support at that time was zero. If the court’s order…”
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