Arizona Revised Statutes

Ariz. Rev. Stat. § 25-414 (2026)

Violation of visitation or parenting time rights; penalties

✓ current as of May 2026
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A. If the court, based on a verified petition and after it gives reasonable notice to an alleged violating parent and an opportunity for that person to be heard, finds that a parent has refused without good cause to comply with a visitation or parenting time order, the court shall do at least one of the following:

1. Find the violating parent in contempt of court.

2. Order visitation or parenting time to make up for the missed sessions.

3. Order parent education at the violating parent's expense.

4. Order family counseling at the violating parent's expense.

5. Order civil penalties of not to exceed one hundred dollars for each violation. The court shall transmit monies collected pursuant to this paragraph each month to the county treasurer. The county treasurer shall transmit these monies monthly to the state treasurer for deposit into the alternative dispute resolution fund established by section 12-135.

6. Order both parents to participate in mediation or some other appropriate form of alternative dispute resolution at the violating parent's expense.

7. Make any other order that may promote the best interests of the child or children involved.

B. Within twenty-five days of service of the petition the court shall hold a hearing or conference before a judge, commissioner or person appointed by the court to review noncompliance with a visitation or parenting time order.

C. Court costs and attorney fees incurred by the nonviolating parent associated with the review of noncompliance with a visitation or parenting time order shall be paid by the violating parent. In the event the custodial parent prevails, the court in its discretion may award court costs and attorney fees to the custodial parent.

 

 

Notes of Decisions
Cited in 12 cases (4 in the last 5 years), 2000–2026 · leading case: Munari v. Hotham, 177 P.3d 860 (Ariz. Ct. App. 2008).
Munari v. Hotham, 177 P.3d 860 (Ariz. Ct. App. 2008). · cites it 9× “§ 25-408 did not leave the grandparent without recourse when a relocating parent violated a visitation order: Grandmother contends that interpreting A.R.S. § 25-408 as excluding non-parents would effectively leave grandparents without a remedy when their court-ordered visitation…”
Lucille v. Dodge, 5 P.3d 925 (Ariz. Ct. App. 2000). · cites it 9× “section 25h110(B). ¶ 19 Dodge further contends that Dr.”
Ball v. Ball, 478 P.3d 704 (Ariz. Ct. App. 2020). · cites it 4× “” ATTORNEY’S FEES AND COSTS ¶30 The superior court ordered Father to pay $3000 of Mother’s attorney’s fees and costs under A.R.S. § 25-414(C). Because the court erred by concluding that Father violated the Parenting Plan’s religious-education provisions, we vacate the fees award.”
Sheehan v. Flower, 170 P.3d 288 (Ariz. Ct. App. 2007). · cites it 4× “3d at 932 (rejecting the argument that A.R.S. § 25-414 applies only to disputes between parents and is inapplicable to grandparent visitation).”
Riepe v. Riepe, 91 P.3d 312 (Ariz. Ct. App. 2004). · cites it 2× “A.R.S. § 25-414(A)(1) (Supp.2003) (The court can "[f]ind the violating parent in contempt of court" if the court "finds that a parent has refused without good cause to comply with the visitation or parenting time order"); A.”
Dellaripa v. Hon. holding/dellaripa (Ariz. Ct. App. 2017). · cites it 4× “”) section] 25- 414” as well as attorneys’ fees and costs pursuant to A.R.S. §§ 25-414 and 25-324. ¶4 In October 2016, Mother filed a petition for contempt for denial of her parenting time, but the petition was merely mailed to counsel for Father and thus not properly served.”
Cleary v. Cordero (Ariz. Ct. App. 2017). · cites it 4× “But A.R.S. § 25-414(A) authorizes the court to sanction those who refuse to comply with a visitation or parenting time order by holding the violator in contempt and assessing court costs and fees.”
Gish v. Greyson, 514 P.3d 937 (Ariz. Ct. App. 2022). · cites it 4× “5 and A.R.S. § 25-414 or modified under Rule 91.”
Treptow v. Vitellaro-Martorell (Ariz. Ct. App. 2026). · cites it 3× “Attorney’s Fees ¶30 Last, Mother challenges the family court’s award of attorney’s fees to Father pursuant to § 25-414. Because the award was premised on both parties’ contempt, we vacate the award so the court may reevaluate each party’s arguments on remand.”
Ziviski v. Collins (Ariz. Ct. App. 2020). · cites it 2× “As set forth in A.R.S. § 25-414(C), court costs “incurred by the nonviolating parent associated with the review of noncompliance with a visitation or parenting time order shall be paid by the violating parent.”
Jf v. Hon. como/cf (Ariz. Ct. App. 2022). · cites it 2× “§ 25-410(B) (judicial supervision); A.R.S. § 25-414(A) (visitation or parenting time violations); A.”
Lopez v. Tinnean (Ariz. Ct. App. 2025). · cites it 2× “See A.R.S. § 25-414(A)(5). ¶14 Whether the court can authorize the use of the specific co-parenting application, authorize the sanctions, or enforce the sanctions is debatable, and Father confesses the court’s error.”
— Ariz. Rev. Stat. § 25-414(A) — 4 cases
Lucille v. Dodge, 5 P.3d 925 (Ariz. Ct. App. 2000). “section 25h110(B). ¶ 19 Dodge further contends that Dr.”
Sheehan v. Flower, 170 P.3d 288 (Ariz. Ct. App. 2007). “3d at 932 (rejecting the argument that A.R.S. § 25-414 applies only to disputes between parents and is inapplicable to grandparent visitation).”
Cleary v. Cordero (Ariz. Ct. App. 2017). “But A.R.S. § 25-414(A) authorizes the court to sanction those who refuse to comply with a visitation or parenting time order by holding the violator in contempt and assessing court costs and fees.”
Jf v. Hon. como/cf (Ariz. Ct. App. 2022). “§ 25-410(B) (judicial supervision); A.R.S. § 25-414(A) (visitation or parenting time violations); A.”
— Ariz. Rev. Stat. § 25-414(A)(1) — 3 cases
Riepe v. Riepe, 91 P.3d 312 (Ariz. Ct. App. 2004). “A.R.S. § 25-414(A)(1) (Supp.2003) (The court can "[f]ind the violating parent in contempt of court" if the court "finds that a parent has refused without good cause to comply with the visitation or parenting time order"); A.”
Munari v. Hotham, 177 P.3d 860 (Ariz. Ct. App. 2008). “§ 25-408 did not leave the grandparent without recourse when a relocating parent violated a visitation order: Grandmother contends that interpreting A.R.S. § 25-408 as excluding non-parents would effectively leave grandparents without a remedy when their court-ordered visitation…”
Cleary v. Cordero (Ariz. Ct. App. 2017). “But A.R.S. § 25-414(A) authorizes the court to sanction those who refuse to comply with a visitation or parenting time order by holding the violator in contempt and assessing court costs and fees.”
— Ariz. Rev. Stat. § 25-414(A)(4) — 1 case
Lucille v. Dodge, 5 P.3d 925 (Ariz. Ct. App. 2000). “section 25h110(B). ¶ 19 Dodge further contends that Dr.”
— Ariz. Rev. Stat. § 25-414(A)(5) — 2 cases
Munari v. Hotham, 177 P.3d 860 (Ariz. Ct. App. 2008). “§ 25-408 did not leave the grandparent without recourse when a relocating parent violated a visitation order: Grandmother contends that interpreting A.R.S. § 25-408 as excluding non-parents would effectively leave grandparents without a remedy when their court-ordered visitation…”
Lopez v. Tinnean (Ariz. Ct. App. 2025). “See A.R.S. § 25-414(A)(5). ¶14 Whether the court can authorize the use of the specific co-parenting application, authorize the sanctions, or enforce the sanctions is debatable, and Father confesses the court’s error.”
— Ariz. Rev. Stat. § 25-414(A)(7) — 1 case
Lucille v. Dodge, 5 P.3d 925 (Ariz. Ct. App. 2000). “section 25h110(B). ¶ 19 Dodge further contends that Dr.”
— Ariz. Rev. Stat. § 25-414(A)(l) — 1 case
Munari v. Hotham, 177 P.3d 860 (Ariz. Ct. App. 2008). “§ 25-408 did not leave the grandparent without recourse when a relocating parent violated a visitation order: Grandmother contends that interpreting A.R.S. § 25-408 as excluding non-parents would effectively leave grandparents without a remedy when their court-ordered visitation…”
— Ariz. Rev. Stat. § 25-414(C) — 3 cases
Ball v. Ball, 478 P.3d 704 (Ariz. Ct. App. 2020). “” ATTORNEY’S FEES AND COSTS ¶30 The superior court ordered Father to pay $3000 of Mother’s attorney’s fees and costs under A.R.S. § 25-414(C). Because the court erred by concluding that Father violated the Parenting Plan’s religious-education provisions, we vacate the fees award.”
Ziviski v. Collins (Ariz. Ct. App. 2020). “As set forth in A.R.S. § 25-414(C), court costs “incurred by the nonviolating parent associated with the review of noncompliance with a visitation or parenting time order shall be paid by the violating parent.”
Treptow v. Vitellaro-Martorell (Ariz. Ct. App. 2026). “Attorney’s Fees ¶30 Last, Mother challenges the family court’s award of attorney’s fees to Father pursuant to § 25-414. Because the award was premised on both parties’ contempt, we vacate the award so the court may reevaluate each party’s arguments on remand.”
— Ariz. Rev. Stat. § 25-414(c) — 1 case
Lucille v. Dodge, 5 P.3d 925 (Ariz. Ct. App. 2000). “section 25h110(B). ¶ 19 Dodge further contends that Dr.”
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