rights rule in Arizona

2009Id. at 198-99 , 115 S.Ct. 797 . ¶ 31 Reversing the Ninth Circuit, which had found the rights under the rule could not be waived, the Supreme Court reasoned that, “absent some affirmative indication of Congress’ intent to preclude waiver, we have presumed that statutory provisions are subject to waiver by voluntary agreement of the parties.” Id. at 201, 211 , 115 S.Ct. 797 .

2009Id. at 198-99 , 115 S.Ct. 797 . ¶ 31 Reversing the Ninth Circuit, which had found the rights under the rule could not be waived, the Supreme Court reasoned that, “absent some affirmative indication of Congress’ intent to preclude waiver, we have presumed that statutory provisions are subject to waiver by voluntary agreement of the parties.” Id. at 201, 211 , 115 S.Ct. 797 .

2016Sec., 203 Ariz. 278, 280, ¶ 3 , 53 P.3d 203, 205 (App. 2002) (“If clear and convincing evidence supports any one of the statutory grounds on which the juvenile court ordered severance, we need not address claims pertaining to the other grounds.”) (citations omitted). ¶7 Because the juvenile court, as the trier of fact, “is in the best position to weigh the evidence, observe the parties, judge the credibility of witnesses, and make appropriate findings,” we will accept the court’s findings of fact unless no reasonable evidence supports those findings, and will only disturb its determination if

2016Sec., 203 Ariz. 278, 280, ¶ 3 , 53 P.3d 203, 205 (App. 2002) (“If clear and convincing evidence supports any one of the statutory grounds on which the juvenile court ordered severance, we need not address claims pertaining to the other grounds.”) (citations omitted). ¶7 Because the juvenile court, as the trier of fact, “is in the best position to weigh the evidence, observe the parties, judge the credibility of witnesses, and make appropriate findings,” we will accept the court’s findings of fact unless no reasonable evidence supports those findings, and will only disturb its determination if

1998Consequently, all property acquired by John Pifer after marriage was his separate property and not subject to Elia’s claims against Stacy Pifer. ¶46 We agree with Elia that all property acquired during marriage is presumed to be community property, see American Express Travel Related Services Co. v. Parmeter, 186 Ariz. 652, 653 , 925 P.2d 1369, 1370 (App.1996), Arizona Revised Statutes Annotated (“A.R.S.”) section 25-211 (1991), and that community property can be reached by creditors to satisfy a community debt.

1998Consequently, all property acquired by John Pifer after marriage was his separate property and not subject to Elia’s claims against Stacy Pifer. ¶46 We agree with Elia that all property acquired during marriage is presumed to be community property, see American Express Travel Related Services Co. v. Parmeter, 186 Ariz. 652, 653 , 925 P.2d 1369, 1370 (App.1996), Arizona Revised Statutes Annotated (“A.R.S.”) section 25-211 (1991), and that community property can be reached by creditors to satisfy a community debt.

1998Libra Group, Inc. v. State, 167 Ariz. 176, 179 , 805 P.2d 409, 412 (App.1991). ¶45 Because the premarital agreement was not shown by Elia to be either involuntary or unconscionable, it prospectively abrogated the Pifers’ respective rights to claim that property acquired during marriage was community property.

1998Libra Group, Inc. v. State, 167 Ariz. 176, 179 , 805 P.2d 409, 412 (App.1991). ¶45 Because the premarital agreement was not shown by Elia to be either involuntary or unconscionable, it prospectively abrogated the Pifers’ respective rights to claim that property acquired during marriage was community property.