Arizona Revised Statutes

Ariz. Rev. Stat. § 25-414 (2026)

Violation of visitation or parenting time rights; penalties

✓ text as last checked Oct. 2026 (this copy records no edition or section history)
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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× “¶31 Both parties request an award of attorney’s fees on appeal. In the exercise of our discretion, we award Father his reasonable attorney’s fees incurred on appeal.”
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.”
Gish v. Greyson, 514 P.3d 937 (Ariz. Ct. App. 2022). · cites it 4× “¶26 The court appointed Father’s chosen COBI “[i]n accordance with ARS Section 25-405(B) .”
Dellaripa v. Hon. holding/dellaripa, No. 1 CA-SA 17-0119 (Ariz. Ct. App. May 16, 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, No. 1 CA-CV 16-0776-FC (Ariz. Ct. App. Oct. 31, 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.”
Treptow v. Vitellaro-Martorell, No. 1 CA-CV 25-0421 FC (Ariz. Ct. App. May 7, 2026). · cites it 3× “¶32 Father requests his appellate attorney’s fees and costs pursuant to Arizona Rule of Civil Appellate Procedure 21(a) and A.R.S. §§ 25-324 and -809(G).”
Ziviski v. Collins, No. 1 CA-CV 19-0249-FC (Ariz. Ct. App. Feb. 25, 2020). · cites it 2× “” In this case, the court found Mother in contempt for violating the juvenile court’s order not to relocate and awarded Father the costs he had incurred for supervised parenting time, as of that date. Although Father contends he orally moved for another award of costs at the…”
Jf v. Hon. como/cf, No. 1 CA-SA 21-0123 (Ariz. Ct. App. July 12, 2022). · cites it 2× “” See Kelly v. Kelly, 252 Ariz. 371, 375, ¶ 18 (App.”
Lopez v. Tinnean, No. 1 CA-CV 24-0703-FC (Ariz. Ct. App. Apr. 22, 2025). · cites it 2× “¶15 Mother finally argues the court abused its discretion by awarding Father final medical decision-making authority for the parties’ children. We do not consider Father’s failure to respond to this argument a confession of error because to do so may be contrary to the…”
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, No. 1 CA-CV 16-0776-FC (Ariz. Ct. App. Oct. 31, 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, No. 1 CA-SA 21-0123 (Ariz. Ct. App. July 12, 2022). “” See Kelly v. Kelly, 252 Ariz. 371, 375, ¶ 18 (App.”
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, No. 1 CA-CV 16-0776-FC (Ariz. Ct. App. Oct. 31, 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, No. 1 CA-CV 24-0703-FC (Ariz. Ct. App. Apr. 22, 2025). “¶15 Mother finally argues the court abused its discretion by awarding Father final medical decision-making authority for the parties’ children. We do not consider Father’s failure to respond to this argument a confession of error because to do so may be contrary to the…”
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). “¶31 Both parties request an award of attorney’s fees on appeal. In the exercise of our discretion, we award Father his reasonable attorney’s fees incurred on appeal.”
Ziviski v. Collins, No. 1 CA-CV 19-0249-FC (Ariz. Ct. App. Feb. 25, 2020). “” In this case, the court found Mother in contempt for violating the juvenile court’s order not to relocate and awarded Father the costs he had incurred for supervised parenting time, as of that date. Although Father contends he orally moved for another award of costs at the…”
Treptow v. Vitellaro-Martorell, No. 1 CA-CV 25-0421 FC (Ariz. Ct. App. May 7, 2026). “¶32 Father requests his appellate attorney’s fees and costs pursuant to Arizona Rule of Civil Appellate Procedure 21(a) and A.R.S. §§ 25-324 and -809(G).”
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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