Arizona Revised Statutes

Ariz. Rev. Stat. § 25-410 (2026)

Judicial supervision

✓ current as of May 2026

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A. Except as otherwise agreed by the parties in writing at the time of the legal decision-making or parenting time order or divorce decree, the parent designated as sole legal decision-maker may determine the child's upbringing, including the child's education, care, health care and religious training, unless, on motion by the other parent, the court, after a hearing, finds that in the absence of a specific limitation of the parent designated as the sole legal decision-maker's authority, the child's physical health would be endangered or the child's emotional development would be significantly impaired.

B. If either parent requests the order, or if all contestants agree to the order, or if the court finds that in the absence of the order the child's physical health would be endangered or the child's emotional development would be significantly impaired, and if the court finds that the best interests of the child would be served, the court shall order a local social service agency to exercise continuing supervision over the case to assure that the custodial or parenting time terms of the decree are carried out. At the discretion of the court, reasonable fees for the supervision may be charged to one or both parents, provided that the fees have been approved by the supreme court.

Notes of Decisions

Cited in 20 cases (5 in the last 5 years), 2000–2025 · 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 30× “See A.R.S. § 25-410(A). We consider whether the family court exceeded its statutory authority by appointing specific treatment professionals for the child here and otherwise limiting the parent's sole legal decision-making authority.”

Hart v. Hart, 204 P.3d 441 (Ariz. Ct. App. 2009). · cites it 19× “Supervised Parenting Time ¶ 15 Mother also contends that the family court abused its discretion by ordering that her parenting time be supervised because (1) Father never requested such a restriction and (2) the court failed to make findings to support this restriction pursuant…”

Lucille v. Dodge, 5 P.3d 925 (Ariz. Ct. App. 2000). · cites it 24× “The best interests of the child are not well-served by an interpretation of § 25-410 that conditions assistance for visitation upon the identity of the party making the request for help.”

Paul E. v. Courtney F., 418 P.3d 413 (Ariz. Ct. App. 2018). · cites it 19× “The court then held that despite Father's sole authority, the circumstances empowered it to limit that authority under A.R.S. § 25-410(A). The court held that "[L.”

Mesa v. O'Connor, 563 P.3d 1179 (Ariz. Ct. App. 2025). · cites it 16× “A Court Has the Authority to Make Post-Decree Appointments under A.R.S. § 25-410(B). ¶37 Father argues the court exceeded its authority by ordering a TI after resolving the parenting issues in the Parenting Order.”

Nicaise v. Sundaram, 418 P.3d 1045 (Ariz. Ct. App. 2018). · cites it 7× “§ 25-401(6) (emphasis added); see also A.R.S. § 25-410(A) (describing baseline rule that "the parent designated as sole legal decision-maker may determine the child's upbringing, including the child's education, care, health care and religious training").”

Sheehan v. Flower, 170 P.3d 288 (Ariz. Ct. App. 2007). · cites it 4× “¶ 15 At issue in Dodge II was whether A.R.S. § 25-410(B) authorized a court to appoint a psychologist to supervise the parties’ compliance with an order providing for grandparent visitation.”

Berrier v. Rountree, 433 P.3d 8 (Ariz. Ct. App. 2018). · cites it 3× “§ 25-401(6), except as the parties agree, in writing, to permit the other parent to decide, A.R.S. § 25-410(A). The court may not substitute its judgment for that of a parent with sole legal decision-making authority except when reallocating authority under § 25-411 or, in…”

McGovern v. McGovern, 33 P.3d 506 (Ariz. Ct. App. 2001). “2000) (Dodge II), Division One held that “the legislature intended to allow the trial court to order supervised visitation under section 25-410(B) in grandparent visitation cases” and rejected the father’s constitutional challenge to the trial court's order appointing a…”

Lisa Friedman v. David C Roels Jr, 418 P.3d 884 (Ariz. 2018). · cites it 2× “" A.R.S. § 25-410(A). ¶ 26 We are not persuaded.”

In re the Marriage of Friedman, 397 P.3d 1063 (Ariz. Ct. App. 2017). · cites it 2× “3d at 591 ; see also A.R.S. § 25-410(A) (court may limit authority of sole legal decision-maker only if “the child’s physical health would be endangered or the child’s emotional development would be significantly impaired”).”

azin/milazzo v. Dresselhuys (Ariz. Ct. App. 2023). · cites it 12× “Section 25-410(A) provides that except as otherwise agreed to by the parties, a parent designated as the sole legal decision-maker “may determine the child’s upbringing” unless the court limits that authority by finding that “the child’s physical health would be endangered or…”

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— Ariz. Rev. Stat. § 25-410(A) — 9 cases

Paul E. v. Courtney F., 439 P.3d 1169 (Ariz. 2019). “See A.R.S. § 25-410(A). We consider whether the family court exceeded its statutory authority by appointing specific treatment professionals for the child here and otherwise limiting the parent's sole legal decision-making authority.”

Paul E. v. Courtney F., 418 P.3d 413 (Ariz. Ct. App. 2018). “The court then held that despite Father's sole authority, the circumstances empowered it to limit that authority under A.R.S. § 25-410(A). The court held that "[L.”

Nicaise v. Sundaram, 418 P.3d 1045 (Ariz. Ct. App. 2018). “§ 25-401(6) (emphasis added); see also A.R.S. § 25-410(A) (describing baseline rule that "the parent designated as sole legal decision-maker may determine the child's upbringing, including the child's education, care, health care and religious training").”

Berrier v. Rountree, 433 P.3d 8 (Ariz. Ct. App. 2018). “§ 25-401(6), except as the parties agree, in writing, to permit the other parent to decide, A.R.S. § 25-410(A). The court may not substitute its judgment for that of a parent with sole legal decision-making authority except when reallocating authority under § 25-411 or, in…”

Lisa Friedman v. David C Roels Jr, 418 P.3d 884 (Ariz. 2018). “" A.R.S. § 25-410(A). ¶ 26 We are not persuaded.”

— Ariz. Rev. Stat. § 25-410(B) — 14 cases

Hart v. Hart, 204 P.3d 441 (Ariz. Ct. App. 2009). “Supervised Parenting Time ¶ 15 Mother also contends that the family court abused its discretion by ordering that her parenting time be supervised because (1) Father never requested such a restriction and (2) the court failed to make findings to support this restriction pursuant…”

Lucille v. Dodge, 5 P.3d 925 (Ariz. Ct. App. 2000). “The best interests of the child are not well-served by an interpretation of § 25-410 that conditions assistance for visitation upon the identity of the party making the request for help.”

Mesa v. O'Connor, 563 P.3d 1179 (Ariz. Ct. App. 2025). “A Court Has the Authority to Make Post-Decree Appointments under A.R.S. § 25-410(B). ¶37 Father argues the court exceeded its authority by ordering a TI after resolving the parenting issues in the Parenting Order.”

Sheehan v. Flower, 170 P.3d 288 (Ariz. Ct. App. 2007). “¶ 15 At issue in Dodge II was whether A.R.S. § 25-410(B) authorized a court to appoint a psychologist to supervise the parties’ compliance with an order providing for grandparent visitation.”

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