Hancock v. Hancock

Court of Appeals of Arizona·Decided August 28, 2026·No. 1 CA-CV 25-0847 FC·Unpublished·Brian Y. Furuya

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UNDER ARIZONA RULE OF THE SUPREME COURT 111(c), THIS DECISION IS NOT PRECEDENTIAL AND MAY BE CITED ONLY AS AUTHORIZED BY RULE.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

AUDREY L. HANCOCK, Petitioner/Appellant,

v.

BRANDON J. HANCOCK, Respondent/Appellee.

No. 1 CA-CV 25-0847 FC

FILED 08-28-2026

Appeal from the Superior Court in Maricopa County No. FC2021-094653

The Honorable Harla M. Davison, Judge, Pro Tempore

AFFIRMED IN PART; VACATED AND REMANDED IN PART

COUNSEL

San Tan Family Law, P.L.C., Queen Creek By Spencer T. Hale, Matthew K. Palfreyman Counsel for Petitioner/Appellant

Brandon J. Hancock, Gilbert Respondent/Appellee

Decision of the Court

MEMORANDUM DECISION

Judge Brian Y. Furuya delivered the decision of the Court, in which Presiding Judge Jennifer M. Perkins and Judge D. Andrew Gaona joined.

F U R U Y A, Judge:

¶1 Audrey L. Hancock (“Mother”) appeals the superior court’s order modifying legal decision-making, parenting time, and child support. For the following reasons, we affirm in part and vacate and remand in part.

FACTS AND PROCEDURAL HISTORY

¶2 Mother and Brandon J. Hancock (“Father”) married in October 2005 and have one adult child and three minor children—B.H., L.H., and K.H. The parties divorced in January 2022 and agreed to joint legal decision-making. The court also ordered Father to pay child support.

¶3 In January 2025, Mother filed a Motion for Post-Decree Temporary Order Without Notice and a Petition to Modify Legal Decision- Making, Parenting Time and Child Support. Mother sought sole legal decision-making and requested supervised parenting time for Father, alleging he psychologically abused the children. Mother also filed an Expedited Motion for Court to Interview Children of the Parties. The court denied Mother’s temporary order motion and motion to interview on an emergency basis. The next month, Father filed a Counter-Petition for Order to Appear Re: Contempt and Enforcement of Parenting Time and Legal Decision-Making Authority Orders.

¶4 The court set an evidentiary hearing to take place on August 11, 2025, to address Mother’s petition and Father’s counter-petition. Two weeks before that hearing, Mother filed a Motion to Continue Trial because she argued she needed time to find legal counsel and the court had not yet addressed her motion to interview. She also asserted in her motion to continue that “one hour is an insufficient amount of time” for the hearing. The court entered a minute entry on August 6 denying the motion to continue and the motion to interview. Later that day, Mother sent Father sixteen exhibits she sought to admit at the hearing. Father then filed a supplemental pre-trial statement, objecting to all of Mother’s exhibits as untimely disclosed.

Decision of the Court

¶5 At the evidentiary hearing on August 11, the court excluded Mother’s exhibits as a sanction for her failure to comply with the rules of disclosure but allowed her to testify about the contents of the exhibits. After considering the evidence and the parties’ testimony, the court awarded Father sole legal decision-making, ordered Mother to pay $570 per month in child support, and found Mother in contempt for violating the court’s previous parenting-time order. The court also imposed a parenting plan for K.H. and L.H. but allowed B.H. to choose her own schedule.

¶6 One month later, Mother filed a Motion to Alter or Amend, requesting a new trial because the court “was not able to weigh all of the appropriate evidence” in its best-interests analysis. The court denied the motion and Mother timely appealed. Father filed a Motion to Dismiss Appeal, arguing Mother’s opening brief was untimely and failed to comply with Arizona Rule of Civil Appellate Procedure (“ARCAP”) 13. We denied the motion to dismiss but permitted Father to re-raise his arguments in his answering brief.

¶7 In November 2025, while Mother’s appeal was pending, she filed a Petition to Modify Child Support. The court held a hearing in March 2026 and later ordered Father to pay $492 per month beginning on January 1, 2026.

¶8 We have jurisdiction pursuant to Article 6, Section 9 of the Arizona Constitution and Arizona Revised Statutes (“A.R.S.”) Section 12- 2101(A)(2).

DISCUSSION

¶9 Mother contends the court erred by (1) excluding her evidence as a sanction; (2) untimely ruling on and denying her motion requesting that the court interview the minor children; (3) denying her request for an expanded hearing; (4) misapplying A.R.S. Section 25-320, the Arizona Child Support Guidelines (“Guidelines”); and (5) failing to consider all evidence related to the parties’ incomes.

¶10 Father argues Mother’s brief does not comply with ARCAP 13 because she fails to cite the applicable standard of review and include citations to the record. See ARCAP 13(a)(7)(B). Failure to comply with ARCAP 13 generally results in waiver. Ramos v. Nichols, 252 Ariz. 519, 522 ¶ 8 (App. 2022). But even if we assume Mother’s brief is deficient, we decline to apply waiver here because the children’s best interests are at issue. See Fadlon v. Cleverly, 262 Ariz. 127, 134 ¶ 17 n.2 (App. 2026) (citing

Decision of the Court

cases), rev. denied (Aug. 7, 2026). We address each of Mother’s arguments in turn.

I. Violation of the Disclosure Rules

A. Timely Disclosure

¶11 Mother argues the court erred in summarily excluding her evidence as a sanction for her violation of disclosure rules because one exhibit was timely disclosed.

¶12 We review the court’s ruling to exclude evidence as a sanction for abuse of discretion. Fadlon, 262 Ariz. at 138 ¶ 41. “In reviewing for an abuse of discretion, the question is not whether the judges of this court would have made an original like ruling, but whether a judicial mind, in view of the law and circumstances, could have made the ruling without exceeding the bounds of reason.” Marquez v. Ortega, 231 Ariz. 437, 441 ¶ 14 (App. 2013) (citation modified). We will affirm unless the court made an error of law or its decision is unsupported by the record. DeLuna v. Petitto, 247 Ariz. 420, 423 ¶ 9 (App. 2019).

¶13 Parties must serve their initial disclosures “not later than 40 days after the filing of the first responsive pleading to a petition.” Ariz. R. Fam. Law P. (“ARFLP”) 49(b)(1). Evidence discovered after this deadline must be disclosed no more than 30 days after discovery. ARFLP 49(b)(2)(B). But if new evidence is discovered less than 30 days before the hearing, it must be disclosed “reasonably in advance of the hearing.” Id.

¶14 Here, Mother first disclosed her list of exhibits in her pre-trial statement on July 28, 2025, approximately two weeks before the hearing. But she did not send Father the actual exhibits—which varied from those listed in her pre-trial statement—until August 6, five days before the hearing. Mother concedes that her disclosure of most exhibits was delinquent. She argues, however, that because one exhibit was not discoverable until July 22, and she disclosed that one exhibit within 30 days of discovery, her disclosure of at least that exhibit was timely.

¶15 But Mother’s argument is flawed because it fails to acknowledge the requirement that disclosure occur “reasonably in advance” when the evidence is discovered less than 30 days before the hearing. See id. July 22 was 20 days before the August 11 hearing. Mother does not cite supporting evidence in the record or argue why five days before trial is “reasonably in advance,” such that her disclosure was timely. Thus, we discern no abuse of discretion and affirm the court’s finding that

Decision of the Court

Mother violated ARFLP 49 by untimely disclosing her evidence, including the one exhibit that was not discoverable until July 22.

B. Prejudice

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