Bennett v. Bennett

CourtCourt of Appeals of Arizona
DecidedOctober 23, 2025
Docket1 CA-CV 25-0260
StatusUnpublished

This text of Bennett v. Bennett (Bennett v. Bennett) is published on Counsel Stack Legal Research, covering Court of Appeals of Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bennett v. Bennett, (Ark. Ct. App. 2025).

Opinion

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 UNDER ARIZONA RULE OF THE SUPREME COURT 111(c), THIS DECISION IS NOT PRECEDENTIAL AND MAY BE CITED ONLY AS AUTHORIZED BY RULE.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 the Matter of:

CARY R. BENNETT, Petitioner/Appellee,

v.

NANCY L. BENNETT, Respondent/Appellant.

No. 1 CA-CV 25-0260 FC FILED 10-23-2025

Appeal from the Superior Court in Maricopa County No. FC2021-051814 The Honorable Colleen E. O’Donnell-Smith, Judge

AFFIRMED

COUNSEL

Reardon House Colton PLC, Scottsdale By Taylor S. House Co-Counsel for Respondent/Appellant

Scottsdale Family Law, PLLC, Scottsdale By Aaron T. Blase Co-Counsel for Respondent/Appellant

DeSoto Law Firm, Phoenix By Rita E. DeSoto Co-Counsel for Petitioner/Appellee Jones, Skelton & Hochuli, Phoenix By Eileen Dennis Gilbride Co-Counsel for Petitioner/Appellee

MEMORANDUM DECISION

Judge Andrew J. Becke delivered the decision of the Court, in which Presiding Judge David B. Gass and Judge Michael J. Brown joined.

B E C K E, Judge:

¶1 Nancy Bennett (“Wife”) appeals an order granting Cary Bennett’s (“Husband”) post-decree petition to modify spousal maintenance and denying Wife’s request for attorneys’ fees. For the following reasons, we affirm.

FACTUAL AND PROCEDURAL HISTORY

¶2 After almost 15 years of marriage, Husband and Wife divorced in February 2022. Their two minor children live with Wife. In the decree, Husband was ordered to pay spousal maintenance of $1,193 per month for 11.5 years to Wife. In December 2023, Husband filed a post- decree petition for termination of spousal maintenance, or in the alternative, modification of spousal maintenance, claiming he was unable to meet his financial obligations.

¶3 Although Husband’s annual income had increased from $107,000 at the time of the decree to $156,000 at the time of the petition, he alleged that his expenses had increased substantially and that the superior court did not consider his increased expenses when it entered the decree. Husband owed more than $44,572 for court ordered therapeutic services including sessions with a therapeutic interventionist (“TI”), a behavioral health assessment of the family, and individual counseling sessions for the children.

¶4 Husband was responsible for the TI fees, while Husband and Wife evenly split the assessment fees. Additionally, Husband was solely responsible for the children’s counseling fees, subject to reallocation.

2 BENNETT v. BENNETT Decision of the Court

¶5 Husband testified that he was unable to pay for both the TI and the children’s counseling. Wife testified that therapy had begun tapering off in late 2023 because Husband was cancelling the appointments. The record did not indicate when, if ever, therapy would end completely.

¶6 Wife testified that she receives social security disability insurance benefits (“SSDI”) of $2,463 per month, and her SSDI had increased since the decree by $2,400 per year. Wife and the children live in a home her parents own, for which Wife paid no rent. Wife testified that she was incurring a debt of $4,000 per month to her parents in lieu of rent, but the court did not find it credible that Wife would pay her parents back, stating: “[Wife] has no plan for doing so nor did she seem concerned about it.”

¶7 Wife’s father submitted an affidavit regarding his financial support for Wife, detailing annual two-week long beach vacations that he provides for Wife and the children. Wife’s father provides “transportation, lodging, food, cash and [his] personal credit cards for everyone in [his] family.” Additionally, he pays for Wife and the children to go on additional trips “during the children’s school breaks” at his expense. Wife’s father also stated that, since Wife and Husband’s separation, he pays for Wife and children to be able to have “special types of expenses and activities they could not otherwise afford.”

¶8 The court denied Husband’s motion to terminate spousal maintenance but granted his request for modification. The court analyzed the factors in A.R.S. § 25-319(B) and found that Husband incurred “significant debt in order to try to repair the relationship [with his] children which he says has made it difficult to pay child support, spousal maintenance, pay his debts, and continue to pay the unexpected fees associated with the TI and counseling for himself and the children.” The court found that Husband was entitled to a reduction of spousal maintenance payments from $1,193 to $600 per month for the remainder of the original term. The court based its ruling on “all of the relevant factors and based upon all of the facts and circumstances presented.”

¶9 Additionally, the court considered Wife’s request for attorneys’ fees and costs. The court found a “substantial disparity of financial resources” between the parties but that neither party had acted unreasonably and denied the request.

3 BENNETT v. BENNETT Decision of the Court

¶10 Wife moved to alter or amend the judgment reducing the spousal maintenance award, which the court denied. Wife now appeals the judgment reducing spousal maintenance and denying her attorneys’ fees and the denial of her motion to alter or amend the judgment. We have jurisdiction under Article 6, Section 9, of the Arizona Constitution and A.R.S. § 12-120.21(A)(1).

DISCUSSION

I. The Superior Court Did Not Abuse Its Discretion in Modifying Spousal Maintenance.

¶11 Wife argues that the superior court abused its discretion when it modified the spousal maintenance award based on a change in circumstances that she alleges no longer applied at the time of the hearing. She argues that Husband’s increased income combined with a cessation of therapy should not have resulted in a reduction in spousal maintenance.

¶12 We review a superior court’s spousal maintenance determinations for abuse of discretion. McClendon v. McClendon, 243 Ariz. 399, 401, ¶ 8 (App. 2017). “We defer to the court’s factual findings unless they are clearly erroneous or unsupported by substantial evidence.” Id.

¶13 A spousal maintenance award “may be modified . . . only on a showing of changed circumstances that are substantial and continuing.” A.R.S. § 25-327(A). “The burden of proving changed circumstances is on the party seeking modification.” Scott v. Scott, 121 Ariz. 492, 494 (1979). The amount and duration of spousal maintenance is determined by consideration of the factors set forth in A.R.S. § 25-319(B). See Cullum v. Cullum, 215 Ariz. 352, 355, ¶ 15 (App. 2007).

¶14 The superior court made findings on each A.R.S. § 25-319(B) factor to determine whether modification of the spousal maintenance award was appropriate. It properly determined whether each factor applied and whether any credible evidence was presented to support it. See Cullum, 215 Ariz. at 355, ¶ 15 (“The [A.R.S. § 25-319(B)] determination by the court is done on a case-by-case basis and some factors will not apply.”).

¶15 Contrary to Wife’s argument, the court considered whether there was a substantial and continuing change of circumstances. The court’s calculations included the possibility that therapy would end.

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Related

Scott v. Scott
591 P.2d 980 (Arizona Supreme Court, 1979)
Cullum v. Cullum
160 P.3d 231 (Court of Appeals of Arizona, 2007)
Magee v. Magee
81 P.3d 1048 (Court of Appeals of Arizona, 2004)
Myrick v. Maloney
333 P.3d 818 (Court of Appeals of Arizona, 2014)
Helland v. Helland
337 P.3d 562 (Court of Appeals of Arizona, 2014)

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Bluebook (online)
Bennett v. Bennett, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bennett-v-bennett-arizctapp-2025.