burden of rebutting presumption (Arizona) · Go Syfert
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burden of rebutting presumption in Arizona

18 Arizona opinions name it 1 courts 1967–2026 5 in the last five years

The cases below were cited by Arizona courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (11)

CaseFollowedCited
McGovern v. McGoverngreen
arizctapp · 2001 · cited in 3 Arizona opinions naming this issue, 2009–2019
2 sentences

2014PORTER/DAY-STRANGE Brown, J., Dissenting children, Troxel v. Granville, 530 U.S. 57, 68 (2000), and a grandparent seeking visitation has the burden of rebutting the presumption “that a decision made by a fit parent to deny or limit visitation was made in the child’s best interest,” McGovern, 201 Ariz. at 177, ¶ 17 , 33 P.3d at 511 . ¶31 Consistent with the recognition of these parental rights, the legislature has “provided nonparents with fewer rights than parents.” Egan, 221 Ariz. at 238, ¶ 31 , 211 P.3d at 1222 ; McGovern, 201 Ariz. at 177, ¶ 16 , 33 P.3d at 511 (noting the legislature’s awa

2014PORTER/DAY-STRANGE Brown, J., Dissenting children, Troxel v. Granville, 530 U.S. 57, 68 (2000), and a grandparent seeking visitation has the burden of rebutting the presumption “that a decision made by a fit parent to deny or limit visitation was made in the child’s best interest,” McGovern, 201 Ariz. at 177, ¶ 17 , 33 P.3d at 511 . ¶31 Consistent with the recognition of these parental rights, the legislature has “provided nonparents with fewer rights than parents.” Egan, 221 Ariz. at 238, ¶ 31 , 211 P.3d at 1222 ; McGovern, 201 Ariz. at 177, ¶ 16 , 33 P.3d at 511 (noting the legislature’s awa

33
Costa v. MacKeygreen
arizctapp · 2011 · cited in 2 Arizona opinions naming this issue, 2025–2026
2 sentences

2026Costa v. Mackey, 227 Ariz. 565, 571, ¶ 12 (App. 2011).

2025Costa v. Mackey, 227 Ariz. 565, 571, ¶ 12 (App. 2011).

22
Emmett McLoughlin Realty, Inc. v. Pima Countygreen
arizctapp · 2006 · cited in 2 Arizona opinions naming this issue, 2014–2020
2 sentences

2020Emmett McLoughlin Realty, Inc. v. Pima Cty., 212 Ariz. 351 , 357 ¶ 24 (App. 2006) (“All decision makers, judges and administrative tribunals alike, are entitled to a presumption of ‘honesty and integrity,’” and the party asserting bias bears the burden of rebutting the presumption of fairness and showing actual bias; “mere speculation regarding bias will not suffice”) (citing Pavlik v. Chinle Unified Sch.

2014See Emmett McLoughlin Realty, Inc. v. Pima Cnty., 212 Ariz. 351, 357, ¶ 24 , 132 P.3d 290, 296 (App. 2006) (“All decision makers, judges 12 SHAH v. AZ BRD DENTAL EXAM Decision of the Court and administrative tribunals alike, are entitled to a presumption of ‘honesty and integrity,’” and the party asserting bias bears the burden of rebutting the presumption of fairness) (citing Pavlik v. Chinle Unified Sch.

12
Troxel v. Granvillegreen
scotus · 2000 · cited in 2 Arizona opinions naming this issue, 2001–2014
2 sentences

2014A presumption exists that “fit parents act in the best interests of their children,” Troxel v. Granville, 530 U.S. 57, 68 , 120 S.Ct. 2054 , 147 L.Ed.2d 49 (2000), and a grandparent seeking visitation has the burden of rebutting the presumption “that a decision made by a fit parent to deny or limit visitation was made in the child’s best interest,” McGovern, 201 Ariz. at 177, ¶ 17 , 33 P.3d at 511 . ¶ 30 Consistent with the recognition of these parental rights, the legislature has “provided nonparents with fewer rights than parents.” Egan, 221 Ariz. at 238, ¶ 31 , 211 P.3d at 1222 ; McGovern,

2014PORTER/DAY-STRANGE Brown, J., Dissenting children, Troxel v. Granville, 530 U.S. 57, 68 (2000), and a grandparent seeking visitation has the burden of rebutting the presumption “that a decision made by a fit parent to deny or limit visitation was made in the child’s best interest,” McGovern, 201 Ariz. at 177, ¶ 17 , 33 P.3d at 511 . ¶31 Consistent with the recognition of these parental rights, the legislature has “provided nonparents with fewer rights than parents.” Egan, 221 Ariz. at 238, ¶ 31 , 211 P.3d at 1222 ; McGovern, 201 Ariz. at 177, ¶ 16 , 33 P.3d at 511 (noting the legislature’s awa

12
Cooper v. Coopergreen
ariz · 1981 · cited in 1 Arizona opinions naming this issue, 2023–2023
1 sentence

2023See Cooper, 130 Ariz. at 259-60 . ¶39 Wife cannot be said to have met her burden of proof.

11
State v. Bohngreen
ariz · 1977 · cited in 1 Arizona opinions naming this issue, 2020–2020
1 sentence

2020State v. Bohn, 116 Ariz. 500, 503 (1977).

11
Comeau v. Arizona State Board of Dental Examinersgreen
arizctapp · 1999 · cited in 1 Arizona opinions naming this issue, 2016–2016
1 sentence

2016Agencies may combine investigation, prosecution, and adjudication functions absent a showing of “actual bias or partiality.” Comeau v. Ariz. State Bd. of Dental Exam’rs, 196 Ariz. 102, 108, ¶ 26 (App. 1999). ¶19 A party asserting bias “bears the burden of rebutting the presumption of fairness and establishing a disqualifying interest.” Pavlik, 195 Ariz. at 152, ¶ 11 .

11
Pavlik v. Chinle Unified School District No. 24green
arizctapp · 1999 · cited in 1 Arizona opinions naming this issue, 2016–2016
1 sentence

2016Agencies may combine investigation, prosecution, and adjudication functions absent a showing of “actual bias or partiality.” Comeau v. Ariz. State Bd. of Dental Exam’rs, 196 Ariz. 102, 108, ¶ 26 (App. 1999). ¶19 A party asserting bias “bears the burden of rebutting the presumption of fairness and establishing a disqualifying interest.” Pavlik, 195 Ariz. at 152, ¶ 11 .

11
Egan v. Fridlund-Hornegreen
arizctapp · 2009 · cited in 1 Arizona opinions naming this issue, 2014–2014
2 sentences

2014PORTER/DAY-STRANGE Brown, J., Dissenting children, Troxel v. Granville, 530 U.S. 57, 68 (2000), and a grandparent seeking visitation has the burden of rebutting the presumption “that a decision made by a fit parent to deny or limit visitation was made in the child’s best interest,” McGovern, 201 Ariz. at 177, ¶ 17 , 33 P.3d at 511 . ¶31 Consistent with the recognition of these parental rights, the legislature has “provided nonparents with fewer rights than parents.” Egan, 221 Ariz. at 238, ¶ 31 , 211 P.3d at 1222 ; McGovern, 201 Ariz. at 177, ¶ 16 , 33 P.3d at 511 (noting the legislature’s awa

2014PORTER/DAY-STRANGE Brown, J., Dissenting children, Troxel v. Granville, 530 U.S. 57, 68 (2000), and a grandparent seeking visitation has the burden of rebutting the presumption “that a decision made by a fit parent to deny or limit visitation was made in the child’s best interest,” McGovern, 201 Ariz. at 177, ¶ 17 , 33 P.3d at 511 . ¶31 Consistent with the recognition of these parental rights, the legislature has “provided nonparents with fewer rights than parents.” Egan, 221 Ariz. at 238, ¶ 31 , 211 P.3d at 1222 ; McGovern, 201 Ariz. at 177, ¶ 16 , 33 P.3d at 511 (noting the legislature’s awa

11
Wolkenstein v. Revillegreen
ca2 · 1982 · cited in 1 Arizona opinions naming this issue, 1999–1999
2 sentences

1999See State v. Jeffers, 135 Ariz. 404, 427 , 661 P.2d 1105, 1128 (1983); Wolkenstein v. Reville, 694 F.2d 35, 42 (2d Cir.1982).

1999See State v. Jeffers, 135 Ariz. 404, 427 , 661 P.2d 1105, 1128 (1983); Wolkenstein v. Reville, 694 F.2d 35, 42 (2d Cir.1982).

11
State v. Jeffersgreen
ariz · 1983 · cited in 1 Arizona opinions naming this issue, 1999–1999
2 sentences

1999See State v. Jeffers, 135 Ariz. 404, 427 , 661 P.2d 1105, 1128 (1983); Wolkenstein v. Reville, 694 F.2d 35, 42 (2d Cir.1982).

1999See State v. Jeffers, 135 Ariz. 404, 427 , 661 P.2d 1105, 1128 (1983); Wolkenstein v. Reville, 694 F.2d 35, 42 (2d Cir.1982).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Arizona. Read the followed side critically anyway.

Also cited on this issue (9)

CaseCitedYears
Marriage of Brebaugh v. Deane green
arizctapp · 2005
1 sentence

2023A.R.S. § 25-211(A); Brebaugh, 211 Ariz. at 97–98, ¶ 6.

12023–2023
Schlaefer v. Financial Management Service, Inc. green
arizctapp · 2000
1 sentence

2021Id.

12021–2021
State v. Garcia-Contreras green
ariz · 1998
1 sentence

2020The critical inquiry in this context is whether the defendant’s absence is voluntary, as “a valid waiver depends upon voluntariness.” Id. ¶20 Under Arizona Rule of Criminal Procedure (“Rule”) 9.1, a court may infer that a defendant’s absence is voluntary, and thus a valid waiver of the right to be present, “if the defendant had actual notice of the date and time of the proceeding, notice of the right to be present, and notice that the proceeding would go forward in the defendant’s absence.” If these requirements are met, the defendant bears the burden of rebutting the presumption that his or h

12020–2020
Lutgert v. Lutgert green
fladistctapp · 1976
1 sentence

2018Id. at 1115-16 .

12018–2018
United States v. Playboy Entertainment Group, Inc. green
scotus · 2000
2 sentences

2001Playboy, 529 U.S. at 817 , 120 S.Ct. 1878 (quoting R.A.V. v. City of St.

2001Playboy, 529 U.S. at 817 , 120 S.Ct. 1878 (quoting R.A.V. v. City of St.

12001–2001
Crafton v. Gibson green
indctapp · 2001
1 sentence

2001As the Indiana appellate court stated in Crafton , “a grandparent seeking visitation has the burden of rebutting the presumption that a decision made by a fit parent to deny or limit visitation was made in the child’s best interest.” 752 N.E.2d at 96-97 . ¶ 18 Second, a trial-court must consider and give “some special weight” to a fit parent’s determination of whether visitation is in the child’s best interest and give “significant weight” to a parent’s voluntary agree *178 ment to some visitation, albeit not as much visitation as the grandparent desires.

12001–2001
Marriage of Gutierrez v. Gutierrez green
arizctapp · 1998
1 sentence

2000Id.

12000–2000
Tyson v. Tyson green
ariz · 1944
2 sentences

1967Tyson v. Tyson, 61 Ariz. 329 , 149 P.2d 674 (1944).

1967Tyson v. Tyson, 61 Ariz. 329 , 149 P.2d 674 (1944).

11967–1967
Porter v. Porter green
ariz · 1948
2 sentences

1967Porter v. Porter, 67 Ariz. 273 , at page 279, 195 P.2d 132 at page 136 (1948), held that this presumption is not dispelled upon the production of any evidence to the contrary and stated, “The Court must be satisfied that the property really is separate before it can state that the presumption has been dispelled.” The burden of rebutting this presumption is on the one claiming the property to be separate and where there is any doubt in the court’s mind, the property will be treated as community property.

1967Porter v. Porter, 67 Ariz. 273 , at page 279, 195 P.2d 132 at page 136 (1948), held that this presumption is not dispelled upon the production of any evidence to the contrary and stated, “The Court must be satisfied that the property really is separate before it can state that the presumption has been dispelled.” The burden of rebutting this presumption is on the one claiming the property to be separate and where there is any doubt in the court’s mind, the property will be treated as community property.

11967–1967

Statutes the citing opinions construe

AZ § Ariz. Rev. Stat. § 25-324 (6) AZ § Ariz. Rev. Stat. § 12-2101 (4) AZ § Ariz. Rev. Stat. § 25-409 (4) AZ § Ariz. Rev. Stat. § 25-211 (3) AZ § Ariz. Rev. Stat. § 25-318 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

IL 341 (1851–2026) TX 190 (1938–2026) IN 91 (1913–2025) PA 62 (1925–2024) LA 48 (1973–2019) CA 47 (1865–2026) WA 47 (1918–2025) NY 46 (1922–2024) VA 45 (1924–2026) NC 37 (1893–2025) MO 35 (1908–2022) CT 31 (1934–2024) MN 30 (1927–2016) OH 29 (1978–2026) MI 27 (1978–2026) MS 26 (1985–2021) AL 20 (1891–2017) AR 20 (1982–2025) AZ 18 (1967–2026) WI 17 (1991–2025) FL 16 (1932–2019) GA 16 (1924–2019) NM 12 (1986–2026) CO 12 (1873–2020) ND 12 (1947–2020) DC 11 (1975–2024) NJ 11 (1954–2020) MD 11 (1990–2023) DE 11 (1962–2022) TN 10 (1980–2021) KY 7 (1955–2025) MT 7 (1990–1999) WV 6 (1983–2024) KS 5 (1977–2021) NV 5 (1990–2023) NE 5 (1903–2006) OR 5 (1952–2025) ID 5 (1986–2018) IA 5 (1925–2018) RI 3 (1979–2005) HI 3 (1983–2001) SC 3 (1941–2026) SD 3 (2002–2023) MA 2 (2003–2008) VT 2 (2015–2017) OK 2 (1953–1994) ME 2 (1998–2020)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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