Arizona Revised Statutes

Ariz. Rev. Stat. § 25-405 (2026)

Interviews by court; professional assistance

✓ text as last checked Oct. 2026 (this copy records no edition or section history)
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25-405. Interviews by court; professional assistance

A. The court may interview the child in chambers to ascertain the child's wishes as to the child's custodian and as to parenting time.

B. The court may seek the advice of professional personnel, whether or not employed by the court on a regular basis. The advice given shall be in writing and shall be made available by the court to counsel, on request, under such terms as the court determines. Counsel may examine as a witness any professional personnel consulted by the court, unless that right is waived.

Notes of Decisions
Cited in 23 cases (11 in the last 5 years), 2000–2026 · leading case: Paul E. v. Courtney F., 439 P.3d 1169 (Ariz. 2019).
Paul E. v. Courtney F., 439 P.3d 1169 (Ariz. 2019). · cites it 11× “and to advise the court pursuant to A.R.S. § 25-405(B). It further ordered that no other clinician could evaluate or treat L.”
Paul E. v. Courtney F., 418 P.3d 413 (Ariz. Ct. App. 2018). · cites it 13× “But we need not resolve any arguable ambiguity in Ehrensaft's role, because even if Ehrensaft was appointed in a wholly advisory capacity, the appointment was impermissible because it was not related to any issue pending before the court.”
Hays v. Gama, 67 P.3d 695 (Ariz. 2003). · cites it 2× “See A.R.S. § 25-405(B) (Supp.2002) (allowing superior court to seek professional advice on child custody issues); see also A.”
Mesa v. O'Connor, 563 P.3d 1179 (Ariz. Ct. App. 2025). · cites it 11× ““[Rule 95] is a procedural rule and cannot enlarge the court’s authority beyond that granted by statute.”
Davis v. Davis, 434 P.3d 152 (Ariz. Ct. App. 2018). · cites it 4× “¶9 “As used in [Rule 12], ‘court’ includes any Conciliation Services department, agency or other third-party professional ordered by the assigned judge to conduct a child interview pursuant to Ariz. Rev. Stat. § 25-405 or the Arizona Rules of Family Law Procedure.”
Brittner v. Lanzilotta, 438 P.3d 663 (Ariz. Ct. App. 2019). · cites it 4× “¶9 While the trial court couched the therapist’s appointment in terms of § 25-405(B) language, we noted that the therapist’s appointment was essentially an order for therapy, and “[a] treating therapist .”
Lucille v. Dodge, 5 P.3d 925 (Ariz. Ct. App. 2000). · cites it 2× “See A.R.S. § 25-405(A)(Supp.l999) ("The court may interview the child in chambers to ascertain the child’s wishes .”
Jordan v. Jordan, 14 A.3d 1136 (D.C. 2011). “16 (2010); Utah R. Jud. Admin. 4-509 (2010); Vt. R. Fam.”
Gish v. Greyson, 514 P.3d 937 (Ariz. Ct. App. 2022). · cites it 5× “§ 25-411(A) because “[a] person shall not make a motion to modify a legal decision-making or parenting time decree earlier than one year after its date, unless the court permits it to be made on the basis of affidavits that there is reason to believe the child’s present…”
McCallum v. Costello, No. 1 CA-CV 25-0710 FC (Ariz. Ct. App. June 22, 2026). · cites it 4× “S. § 25-405(A); Ariz. R. Fam. Law P. 12(a); J.”
Jorgenson v. Giannecchini, No. 1 CA-CV 20-0009-FC (Ariz. Ct. App. May 6, 2021). · cites it 3× “The court did so in this case, and both a court-appointed advisor and the psychologist who evaluated Mother testified not only that long-term therapy could benefit her but that she may need supervision to ensure she progresses in such treatment.”
Kazi v. Saleem, No. 1 CA-CV 16-0475-FC (Ariz. Ct. App. June 8, 2017). · cites it 2× “Because the family court may seek professional advice on child custody issues, see A.R.S. §§ 25-405(B) (2017), -406 (2017); Hays v.”
Ariz. Rev. Stat. § 25-405(A): 4 cases
Lucille v. Dodge, 5 P.3d 925 (Ariz. Ct. App. 2000). “See A.R.S. § 25-405(A)(Supp.l999) ("The court may interview the child in chambers to ascertain the child’s wishes .”
Paul E. v. Courtney F., 418 P.3d 413 (Ariz. Ct. App. 2018). “But we need not resolve any arguable ambiguity in Ehrensaft's role, because even if Ehrensaft was appointed in a wholly advisory capacity, the appointment was impermissible because it was not related to any issue pending before the court.”
McCallum v. Costello, No. 1 CA-CV 25-0710 FC (Ariz. Ct. App. June 22, 2026). “S. § 25-405(A); Ariz. R. Fam. Law P. 12(a); J.”
Pulkrabek v. Pulkrabeck, No. 1 CA-CV 22-0204-FC (Ariz. Ct. App. Nov. 3, 2022).
Ariz. Rev. Stat. § 25-405(B): 15 cases
Paul E. v. Courtney F., 439 P.3d 1169 (Ariz. 2019). “and to advise the court pursuant to A.R.S. § 25-405(B). It further ordered that no other clinician could evaluate or treat L.”
Paul E. v. Courtney F., 418 P.3d 413 (Ariz. Ct. App. 2018). “But we need not resolve any arguable ambiguity in Ehrensaft's role, because even if Ehrensaft was appointed in a wholly advisory capacity, the appointment was impermissible because it was not related to any issue pending before the court.”
Hays v. Gama, 67 P.3d 695 (Ariz. 2003). “See A.R.S. § 25-405(B) (Supp.2002) (allowing superior court to seek professional advice on child custody issues); see also A.”
Mesa v. O'Connor, 563 P.3d 1179 (Ariz. Ct. App. 2025). ““[Rule 95] is a procedural rule and cannot enlarge the court’s authority beyond that granted by statute.”
Brittner v. Lanzilotta, 438 P.3d 663 (Ariz. Ct. App. 2019). “¶9 While the trial court couched the therapist’s appointment in terms of § 25-405(B) language, we noted that the therapist’s appointment was essentially an order for therapy, and “[a] treating therapist .”
Ariz. Rev. Stat. § 25-405(a): 1 case
Gallegos v. Wildenstein, No. 1 CA-CV 24-0899-FC (Ariz. Ct. App. Oct. 1, 2025).
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