Arizona Court of Appeals DIV1: No. 1 CA-CV 23-0805-FC Filed October 31, 202
Vonda Douros v. Brittany Morse
ISSUES: Application of Arizona’s third-party visitation statute (A.R.S. § 25-409) in light of parent’s objection; superior court authority under A.R.S. § 25-409 to order the mother to take the child to counseling; Constitutionality of the superior court’s third-party visitation award
DECISION: The visitation award was vacated and remanded to the superior court to adjust it consistent with the Court of Appeals’ decision.
NOTE: Judge Catlett delivered a separate special concurrence, stressing the deference courts must apply when analyzing a fit parent’s objection to third-party visitation