In Re Dependency as to A.O.

NOTICE: NOT FOR OFFICIAL PUBLICATION.
UNDER ARIZONA RULE OF THE SUPREME COURT 111(c), THIS DECISION IS NOT PRECEDENTIAL
AND MAY BE CITED ONLY AS AUTHORIZED BY RULE.

IN THE
ARIZONA COURT OF APPEALS
DIVISION ONE

IN RE DEPENDENCY AS TO A.O.

No. 1 CA-JV 25-0146
FILED 04-30-2026

Appeal from the Superior Court in Maricopa County
No. JD536046
The Honorable Suzanne E. Cohen, Judge

AFFIRMED

COUNSEL

Ashley P., Apache Junction
Appellant

Slaton Roebuck PLLC, Scottsdale
By Sandra L. Slaton
Counsel for Appellant Leah M.

David W. Bell Attorney at Law, Higley
By David W. Bell
Counsel for Appellee
IN RE DEPENDENCY AS TO A.O.
Decision of the Court

Maricopa County Office of Legal Advocate, Phoenix
By Amanda L. Adams
Counsel for Appellee Child

MEMORANDUM DECISION

Presiding Judge Michael S. Catlett delivered the decision of the Court, in
which Judge Angela K. Paton and Judge Jennifer M. Perkins joined.

C A T L E T T, Judge:

¶1 Leah M. (“Grandmother”) and Ashley P. (“Aunt”)
(collectively with Grandmother, “Petitioners”) both petitioned the juvenile
court to have A.O. (“Child”) declared dependent as to Richard O.
(“Father”). The juvenile court denied those petitions. Petitioners appeal.
Because the record supports the juvenile court’s decision, we affirm.

FACTS AND PROCEDURAL HISTORY

¶2 Father and Melissa O. (“Mother”) had Child in August 2017.
Mother died in August 2023, when Child was six years old. Police
determined Mother committed suicide, but Petitioners believe Father killed
her. They also believe Child, who has a heart condition known as Tetralogy
of Fallot, is medically fragile and may be critically ill because of Father’s
alleged medical neglect.

¶3 In December 2023, Grandmother petitioned for in loco parentis
legal decision-making authority, and Aunt petitioned for visitation. Those
cases were consolidated and remain active in the family court.

¶4 In October 2024, Grandmother filed a dependency petition.
The juvenile court ordered the Department of Child Safety (“Department”)
to investigate her allegations of abuse and neglect. An investigator with the
Department interviewed Father, Child, Child’s half sibling, Grandmother,
and Aunt. The Department reported to the court that Father was meeting
all of Child’s basic medical, behavioral health, and parenting needs. The
Department concluded Father’s home was safe and appropriate, and it did
not observe any signs that Father abused alcohol. The Department
recommended Child remain in Father’s custody.

¶5 At the initial dependency hearing in November 2024, the
Department asked to be excused from the case, and Child’s attorney moved
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to dismiss the dependency. The juvenile court dismissed that petition.
Grandmother petitioned for special action relief; we declined jurisdiction.

¶6 In March and April 2025, Petitioners filed new dependency
petitions. Their petitions made similar allegations: (1) Father neglected
Child’s medical and behavioral health needs; (2) Father abused alcohol; and
(3) Father physically, mentally, and emotionally abused Child.

¶7 The juvenile court ordered the Department to conduct
another investigation. The Department’s again recommended that Father
maintain custody of Child. The Department’s investigator noted that the
Department had interviewed Child for the fifth time, and Child “has not
disclosed maltreatment[.]” The investigator expressed concern that
exposing Child to “unnecessary questioning without a change in family
circumstances is likely to have a negative impact on [Child’s] emotional
well-being.”

¶8 In August 2025, the juvenile court held a three-day
dependency adjudication hearing. The court heard testimony from Father,
Grandmother, Aunt, two Department investigators, Father’s former
girlfriend, a private investigator, and two expert witnesses.

¶9 After the hearing, the juvenile court denied both petitions.
The court found Petitioners “have little credibility.” The court also
expressed concern that their “vendetta against [F]ather could be causing
emotional stress in [Child].” The court found there was “no credible
evidence” that Father abused Child.

¶10 Petitioners moved to alter or amend that decision. The
juvenile court denied those motions, and Petitioners timely appealed.

JURISDICTION

¶11 Petitioners ask us to treat their opening briefs as petitions for
special action and accept special action jurisdiction. They contend Father is
endangering Child by neglecting her medical care and Grandmother claims
“the standard appellate process” is too slow to protect Child’s welfare.

¶12 To initiate a special action, a petitioner must ordinarily file a
petition for special action. See RPSA 14(a). Compliance with these rules
alerts this court to the request for special action relief and ensures a panel
of judges promptly reviews the matter.

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¶13 Petitioners have initiated three petitions for special action
concerning these dependency proceedings. See 1 CA-SA 25-0011, 1 CA-SA
25-0103, and 1 CA-SA 25-0106. Yet neither Petitioner filed a separate
petition for special action challenging the juvenile court’s dependency
decision. As a result, the parties have now fully briefed this appeal. At this
point in the appellate process, converting this appeal into a special action
would not expedite the decision. Moreover, the “standard appellate
process” is not too slow to address the issues Petitioners raise. See Ariz.
R.P. Juv. Ct. 602(a). Because Petitioners have an adequate remedy by direct
appeal, we decline to accept special action jurisdiction. See RPSA 12(a). We
instead exercise appellate jurisdiction under A.R.S. §§ 8-235(A), 12-
120.21(A)(1).

DISCUSSION

¶14 A dependency determination requires proof by a
preponderance of the evidence based on “the circumstances as they exist at
the time of the dependency adjudication.” Shella H. v. Dep’t of Child Safety,
239 Ariz. 47, 48 ¶ 1 (App. 2016); A.R.S. § 8-844(C)(1). A child’s best interests
is the primary concern in a dependency case. Joelle M. v. Dep’t of Child Safety,
245 Ariz. 525, 527 ¶ 10 (App. 2018). A child is dependent if the parent does
not provide “proper and effective parental care and control[.]” A.R.S. § 8-
201(15)(a)(i). A dependent child is also one “whose home is unfit by reason
of abuse [or] neglect” by the parent. A.R.S. § 8-201(15)(a)(iii). “Neglect” is
“[t]he inability or unwillingness of a parent . . . to provide that child with
. . . medical care” which “causes substantial risk of harm to the child’s
health or welfare[.]” A.R.S. § 8-201(25)(a); see also A.R.S. § 8-819(1)
(“consideration shall be given to” a parent’s “alcohol abuse” when
“determining if a child is neglected”).

I. Precluding Witnesses and Evidence

¶15 Petitioners argue the juvenile court abused its discretion by
precluding testimony from Child’s physicians and medical records
containing hearsay. We will not disturb the court’s evidentiary rulings
without a clear abuse of discretion and resulting prejudice. Johnson v.
Provoyeur, 245 Ariz. 239, 241–42 ¶ 8 (App. 2018).

A. Disclosure Sanctions

¶16 Relying on Hays v. Gama and Rule of Procedure for the
Juvenile Court (“Rule”) 301(b) and Rule 315(g), Grandmother insists that
precluding Child’s doctors from testifying was error because doing so

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significantly impacted the court’s ability to determine Child’s best interests.
205 Ariz. 99, 103–04 ¶¶ 21–23 (2003).

¶17 In Hays, the family court imposed evidentiary sanctions on
the mother in a child-custody matter due to contempt of court. Id. at 101
¶ 9. Our supreme court vacated those sanctions, explaining the discovery
rules did not authorize the exclusion because the family court had not
determined that the mother violated any discovery order, and “the
sanctions were imposed pursuant to the court’s inherent contempt power.”
Id. at 101–02 ¶¶ 14–16, 104 at ¶ 24. The court concluded that excluding the
evidence “effectively preclude[d] potentially significant information from
being considered in the custody determination” and impacted the family
court’s ability to determine the child’s best interests. Id. at 103–04 ¶ 22.

¶18 Here, the juvenile court did not abuse its discretion by
precluding untimely disclosed witnesses. At a pretrial hearing in June 2025,
Grandmother moved to continue the adjudication hearing because she
hired new counsel and failed to file a timely disclosure statement. The court
granted the motion over Father’s objection. But the court told Grandmother
that “the disclosure statement and any evidence must be disclosed by
Friday [June 13, 2025]. The disclosure is closed down as of Friday.
Anything sent after that would not be admitted.” Grandmother filed a
timely disclosure statement listing 30 witnesses, which she later
supplemented after the disclosure deadline to add three more witnesses.

¶19 In August 2025, two days before the adjudication hearing, the
juvenile court held a status conference to address evidentiary issues. The
court observed that Petitioners had disclosed 33 witnesses. The court also
noted that Grandmother had moved for Dr. Ellsworth, Child’s cardiologist,
to appear virtually, but that he was not listed among her 33 witnesses. The
court told Grandmother that “if he’s not disclosed, he’s not testifying.
Discovery is closed.” The court told Petitioners to pare down the witness
list and provide an updated list to counsel by the close of business the next
day. Rather than trimming witnesses, Grandmother filed a second
supplemental disclosure statement adding Child’s cardiologist and
pediatrician. At the adjudication hearing the next day, the court sustained
Father’s objection to the untimely witnesses.

¶20 Under these circumstances, the juvenile court’s sanctions
were reasonable because Grandmother and Aunt did not show good cause
for their non-compliance with Rule 315 and the court’s disclosure orders.
See Johnson, 245 Ariz. at 243 ¶ 16 (noting the parent’s failure to show good
cause for non-compliance). We also reject Grandmother’s contention that

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her motion for Dr. Ellsworth to appear virtually, which the court granted
two days before the hearing, substituted for proper disclosure.

B. Ability to Assess Child’s Best Interests

¶21 Grandmother also relies on James A. v. Department of Child
Safety, to argue the juvenile court abused its discretion by precluding their
evidence because they did not have other evidence that could substitute for
Child’s physicians and medical records. 244 Ariz. 319 (App. 2018).

¶22 In James A., the juvenile court denied the father’s motion to
continue the termination hearing and precluded the father’s expert report
for being two days late. Id. at 322 ¶¶ 9–10. We reversed, holding that
“[b]ecause a court has an ‘overriding obligation to consider the best
interests of the child,’” the court erred “by precluding the potentially
outcome-determinative” expert report. Id. at 322 ¶ 13. We noted the parent
possessed no other evidence that could substitute for that report. Id. ¶ 12.

¶23 In Johnson, however, we upheld the juvenile court’s exclusion
of an untimely supplemental expert report because the expert’s testimony
regarding the original report, along with other evidence, gave the court
“sufficient information to assess the children’s best interests.” 245 Ariz. at
243–44 ¶¶ 16–17. We held that the court may impose a sanction, including
preclusion, for untimely disclosure, but when it does so, the court must
have sufficient information to assess the child’s best interests. Id. at ¶ 17.
We also warned that a party may not use Hays “to flout multiple disclosure
deadlines without good cause[.]” Id. at 245 ¶ 20.

¶24 The juvenile court here had sufficient medical information to
assess Child’s best interests and the allegations of medical neglect. Father
testified about Child’s medical issues. He explained that Child had
Tetralogy of Fallot, which was corrected at birth. He explained she may
need another heart surgery and is in a yearly monitoring program. He
explained that Child dances competitively and has no exercise restrictions.
He acknowledged that he was late taking Child to a heart doctor, which he
attributed to this litigation.

¶25 Father also testified about Child’s pediatrician visits. He
explained that Child does not have asthma, but she has been treated for it
in the past. He testified he took Child to the pediatrician in 2024 because
she had a urinary tract infection and constipation. He testified Child has
seasonal eczema, which he treats with prescription creams.

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¶26 Petitioners called a pediatric hospitalist, Dr. Ralph Martello,
to testify as an expert about Child’s medical issues. Dr. Martello testified
about Child’s diagnosis with Tetralogy of Fallot, her skin condition, her
2024 echocardiogram, and her frequent visits to the school nurse. He
testified that at Child’s last cardiologist appointment, her doctor was very
encouraged about how Child was doing and encouraged the family to treat
her normally without any restrictions. He added that her echocardiogram
showed her “prior surgeries were holding up well and her heart was
functioning very nicely.” But he testified that he was “very concern[ed]”
Child was overdue for her annual follow-up appointment with her
cardiologist.

¶27 Dr. Martello also reviewed the pediatrician’s visit summary
from February 2024 and testified about the pediatrician’s treatment of
Child’s other medical issues. The court admitted Dr. Martello’s written
report into evidence.

¶28 The juvenile court also considered Child’s school nurse
records. The court found that Child visited the school nurse 24 times
between September 2023 and December 2024. The court noted that Dr.
Martello testified that the number of visits is “unusual and could indicate
medical or mental health concerns.” The court observed that Mother died
in August 2023 and Father was addressing Child’s mental health through
therapy. The court found that Child had seen the school nurse only three
times after January 2025, and that “[w]hatever was causing [Child] to visit
the nurse so often after her mother died has seemed to resolve.”

¶29 The Department’s first court report contained visit summaries
from Child’s cardiologist appointments beginning after her surgery in
December 2017 and continuing through March 2024. The Department’s
case notes also summarized those appointments and were admitted into
evidence. Consistent with Father’s and Dr. Martello’s testimony, these
records indicate that Child was doing well and the family should treat her
as a normal child without any physical restrictions or limitations.

¶30 In sum, the juvenile court had sufficient information to assess
Child’s best interests even after precluding untimely disclosed witnesses.
See Johnson, 245 Ariz. at 243 ¶ 17.

C. Precluding Hearsay Records

¶31 Grandmother argues the juvenile court abused its discretion
by precluding Child’s medical records, which she asserts “compound[ed]
violations” of Hays and Rules 301(b) and 315(g). Grandmother contends
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the pediatrician’s visit summaries would not have been hearsay if the court
had permitted Child’s physician to testify about the documents. See Ariz.
R. Evid. 803(6)(D). Alternatively, she argues these records were admissible
to impeach Father.

¶32 Petitioners were responsible for presenting evidence to
support their allegations. See A.R.S. § 8-844(C)(1). The record shows
Grandmother and Aunt had Child’s pediatric records since at least March
2025, when Aunt attached them to her dependency petition. If they
intended to admit Child’s medical records, they needed to obtain certified
copies. Ariz. R. Evid. 803(6)(D). Furthermore, the juvenile court did not err
by refusing to allow Grandmother to impeach Father with medical records
that he did not author. See Ariz. R. Evid. 607–609 (impeachment), and 806
(prior-inconsistent statements).

II. Due Process

¶33 Grandmother next argues the juvenile court deprived her of
due process and a meaningful opportunity to “fully argue and present
evidence regarding the medical neglect allegations within her dependency
petition.” She relies on Matter of Guardianship of A.K., 258 Ariz. 336, 343 ¶ 17
(App. 2024). There, we noted a “court violates a litigant’s due process rights
if it affords the party no meaningful opportunity to be heard.” Id. at 343
¶ 20 (citations omitted). But here, the court gave Grandmother three days
to present her case, which was what the parties requested. That was ample
time for Grandmother to present her case.

¶34 Aunt likewise argues the juvenile court denied her due
process because it precluded her from meaningfully participating in the
adjudication hearing. She contends the court did not admit the 27 exhibits
she attached to her petition. But she never submitted those exhibits to be
marked at the hearing nor offered them for admission into evidence. After
Grandmother rested, the court asked Aunt if she wanted to call any
witnesses or present evidence. She responded, “No, ma’am.” The juvenile
court did not violate either Grandmother’s or Aunt’s due process rights.

III. Child’s Counsel

¶35 Aunt argues the juvenile court erred by permitting Child’s
counsel to oppose the dependency petitions and by allowing counsel to
object to Aunt’s evidence and witnesses. Aunt waived this argument by
not making it in the juvenile court. See Christy C. v. Ariz. Dep’t of Econ. Sec.,
214 Ariz. 445, 452 ¶ 21 (App. 2007) (“We generally do not consider
arguments raised for the first time on appeal.”). Aunt also appears to claim
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in her reply brief that the court never ruled on her request to appoint Child
a guardian ad litem. We will not consider arguments made for the first time
in a reply brief. Dawson v. Withycombe, 216 Ariz. 84, 111 ¶ 91 (App. 2007).

¶36 Waiver aside, Aunt incorrectly characterizes Child’s counsel
as a “best interests attorney.” The juvenile court must appoint an attorney
for all children in dependency or termination cases. See A.R.S. § 8-221(A),
(F); Ariz. R.P. Juv. Ct. 303(c). Under Juvenile Rule 303(c), “[t]he child’s
attorney owes the same duties, undivided loyalty, confidentiality, and
competent representation, to the child as is due an adult client.” A child’s
attorney must advocate for the child consistently with the child’s objectives
or expressed preferences. Ariz. R.P. Juv. 306(a)(1)(A); see also Ariz. R. Sup.
Ct. 42, ER 1.2(a).

¶37 Here, Child’s counsel met with Child multiple times without
Father present. Child’s counsel reported to the juvenile court that Child’s
“position is she wishes . . . to remain with [Father].” Child’s position was
consistent with her statements to Department investigators that Father
loves her, they get along well, she feels safe at home, and there is nothing
she would change about him. Given Child’s position, her counsel
appropriately advocated for her during the adjudication hearing.

IV. Sufficiency of the Evidence

¶38 We review dependency findings for an abuse of discretion.
Louis C. v. Dep’t of Child Safety, 237 Ariz. 484, 488 ¶ 12 (App. 2015). We view
the evidence in the light most favorable to upholding the juvenile court’s
dependency finding and will affirm the court’s finding unless “no
reasonable evidence supports it.” Shella H., 239 Ariz. at 48, 50 ¶¶ 1 n.1, 13
(citations omitted); cf. Brionna J. v. Dep’t of Child Safety, 255 Ariz. 471, 478
¶ 30 (2023). We do not reweigh the evidence or reevaluate the credibility
of witnesses. Maria G. v. Dep’t of Child Safety, 253 Ariz. 364, 366 ¶ 8 (App.
2022).

A. Substance Abuse

¶39 Grandmother argues the juvenile court abused its discretion
by making incorrect and inconsistent findings about Father’s drinking. The
court found the following:

Father admittedly drinks alcohol; however, he was untruthful
about drinking alcohol and driving with [Child]. Consuming
alcohol and driving intoxicated is illegal. Consuming alcohol
and driving while not intoxicated is not illegal. Father

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admitted to drinking at a party in February 2025 but denied
driving [Child]. This was untrue. However, there was no
evidence presented he was intoxicated.

¶40 Grandmother contends the court made an arbitrary
distinction between “[c]onsuming alcohol and driving intoxicated” and
“[c]onsuming alcohol and driving while not intoxicated.” She further
asserts it is unlawful under A.R.S. § 28-1381(A)(1) to drive under the
influence of alcohol if the person is “impaired to the slightest degree.” She
insists the court’s findings about Father’s drinking support information she
gave Dr. Martello that in February 2025 Father drove with Child while
intoxicated “prompting a renewed [Department] intervention.”

¶41 Aunt hired private investigators to surveil Father over about
10 days between December 2024 and February 2025. At the hearing, one of
the private investigators testified that he observed Father drinking alcohol
at a birthday party at a restaurant in February 2025. He further testified
that Father left the restaurant and drove home with Child in the vehicle. He
described how, as soon as Father left the restaurant’s parking lot, the police
began following Father. The private investigator reported that the police
followed Father for about 20 minutes as he drove home, but the private
investigator never saw the police pull Father over. Based on this testimony,
the juvenile court reasonably inferred that the police would have stopped
Father if they thought he was impaired.

¶42 Reasonable evidence also supports the juvenile court’s
findings that “there was no credible evidence presented that [F]ather has
an alcohol abuse problem,” and that Petitioners provided their expert
witness with “exaggerated and misleading information” about Father’s
drinking. For instance, Father’s former girlfriend testified that he drank at
a party in December 2024, but he did not appear impaired when driving his
daughter home. She testified she would have called him an Uber if she felt
he was under the influence. Grandmother also testified that at her birthday
party in July 2023, Father drank excessively and then drove home with
Child, Mother, and Grandmother in the vehicle. But the court noted that
because Grandmother “got in the car, the court can only assume [F]ather
was not intoxicated.”

B. Child’s Therapy

¶43 Grandmother argues the juvenile court abused its discretion
by finding that her expert witness, Dr. Kathie Mathis, a clinical
psychologist, had “little credibility” and by giving Dr. Mathis’ testimony

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“no weight.” She asserts the court should have given greater weight to Dr.
Mathis’ opinion that Child’s therapy was below the standard of care and
amounted to “clinical neglect.”

¶44 The juvenile court found Dr. Mathis reviewed several reports
and relied heavily on biased information from Petitioners. The court also
determined that Dr. Mathis made several unsupported and exaggerated
assertions. Dr. Mathis, for example, opined that Father was a “self-
admitted abuser,” which was false. She elaborated that the basis for this
opinion was that he had told police he argued with Mother and
acknowledged he needed patience and to calm down. She testified that
Child’s statement to a Department investigator—that three times Father
dragged her to her room and made her stay in her room until she calmed
down—showed that Father abused Child and exercised “relationship
terrorism” and committed illegal “hostage-taking and barricading.”

¶45 The juvenile court also found that Dr. Mathis ignored Child’s
multiple positive statements about Father, including that she told
Department investigators that Father loves her, they get along well, she
feels safe at home, and there is nothing she would change about him.
Reasonable evidence supports the court’s findings and credibility
assessments concerning Dr. Mathis.

¶46 Grandmother asserts that Dr. Mathis’ testimony established
that better therapy is available to address Child’s special needs, and that
the juvenile court erred by finding Grandmother failed to prove Child’s
current therapy presented an unreasonable risk of harm to Child. To the
contrary, reasonable evidence also supports the juvenile court’s conclusion
that Child’s therapy did not threaten her health or welfare. Child reported
to the Department that she sees her therapist every Friday and enjoys
therapy because her therapist is fun and they do activities and read books
together. The juvenile court found Child “likes her therapist and wants to
stay working with her.” The court astutely observed that Child’s comfort
with her therapist is vital for effective treatment. The court also carefully
reviewed Child’s therapy records and her school nurse records.

C. Child’s Skin Condition

¶47 Aunt argues the juvenile court mischaracterized Dr.
Martello’s testimony. She asserts Dr. Martello testified that Child did not
have eczema and that the court was wrong to find Father “is treating
[Child’s] skin condition with a cream, one of the treatments suggested
would be appropriate by Dr. Martello.” Aunt says Dr. Martello “testified

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the lesions on A.O.’s face, back, and legs were not eczema, yet the court
allowed this condition to remain unresolved and improperly untreated,
despite medical evidence that it’s an autoimmune disorder which, when
combined with [A.O.’s] Tetralogy of Fallot, poses a serious and potentially
life-threatening risk.”

¶48 Dr. Martello testified Child’s skin condition did not look like
“classic” eczema. He noted that eczema “can potentially present on the
face,” but that Child may have a “a condition such as vitiligo.” He testified
that there are overlapping treatments for these skin conditions, including
steroid creams, ointments, and phototherapy. He admitted that he has
never met Child and has never communicated with her doctors.

¶49 Father testified that Child’s pediatrician prescribed a cream
for her eczema. He explained that he has treated Child’s skin condition
with these creams every summer since 2018. The Department investigator
testified that Father showed her the cream he uses for Child’s skin
condition, and that it was in a prescription box with Child’s name on it.
Reasonable evidence supports the juvenile court’s finding that Father was
adequately addressing Child’s skin condition.

D. Department After-Care Plan

¶50 Aunt argues the juvenile court erred by finding that an
unsigned 2024 Department after-care plan did not bind Father. She argues
the plan was essential and prohibited Father from drinking alcohol while
caring for Child.

¶51 There is no evidence that the Department made the plan a
condition for Father to retain custody of Child. Father did not sign the plan.
And when the Department closed its investigation in May 2024 and found
the child abuse report “unsubstantiated,” the Department recommended
only “[c]ommunity [r]esources” for the family. The juvenile court correctly
concluded that “[t]here was no evidence presented that [the Department]
made this plan a condition for anything regarding caring for [Child], or that
[F]ather agreed to it.”

E. School Nurse Records

¶52 Aunt argues the juvenile court erred by delaying the
admission of the school nurse records and only admitting them after she
rested her case. She also asserts the court erred by relying on incomplete
school nurse records. She further asserts the records do not support the

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court’s finding that prior to her mother’s death, Child visited the school
nurse eight times between August 2022 and March 2023.

¶53 During the hearing, Aunt moved to admit the school nurse
records. Child objected because the records were not certified, and the
juvenile court sustained the objection. Later, Grandmother moved to admit
the school nurse records, which the school principal had certified. The
court admitted those records at the end of the hearing. A few days later,
Grandmother moved to supplement the school nurse records because she
alleged they were incomplete. But the court denied the motion as untimely
because the “evidence was closed at the conclusion of the three-day
evidentiary hearing.”

¶54 Aunt had a reasonable opportunity to address the school
nurse records during the hearing but did not do so. After the records were
certified, Aunt never moved to admit them. And before closing evidence,
the juvenile court asked Aunt if she wanted to present additional testimony
or evidence, but she declined. The school nurse records also reasonably
support the court’s findings. The court did not err.

V. Incorrect and Hallucinated Citations

¶55 Aunt’s opening brief cites legal authority that is either
incorrect or non-existent. The juvenile court similarly observed that Aunt’s
briefs contained incorrect legal citations. Arizona Rule of Civil Appellate
Procedure 13(a)(7) requires that briefs’ arguments contain citations to legal
authority. The integrity of the appellate process depends on accurate and
honest advocacy. We “hold unrepresented litigants in Arizona to the same
standards as attorneys and do not afford them special leniency.” Ramos v.
Nichols, 252 Ariz. 519, 522 ¶ 8 (App. 2022). We thus find Aunt’s brief in
violation of Rule 13(a)(7) and caution that in the future, failure to provide
accurate legal authority may result in sanctions.

CONCLUSION

¶56 We affirm.

MATTHEW J. MARTIN • Clerk of the Court
FILED: JR

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