In Re Term of Parental Rights as to K.C.

Court of Appeals of Arizona·Decided February 4, 2026·No. 1 CA-JV 25-0136·Unpublished·Veronika Fabian

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 UNDER ARIZONA RULE OF THE SUPREME COURT 111(c), THIS DECISION IS NOT PRECEDENTIAL AND MAY BE CITED ONLY AS AUTHORIZED BY RULE.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 TERMINATION OF PARENTAL RIGHTS AS TO K.C.

No. 1 CA-JV 25-0136 FILED 02-04-2026

Appeal from the Superior Court in Maricopa County No. JS521069 The Honorable Suzanne E. Cohen, Judge

VACATED AND REMANDED

COUNSEL

Maricopa County Legal Defender’s Office, Phoenix By Jamie R. Heller Counsel for Appellant Father Kurt C.

Shelby R. Pro Per Appellee Mother

Law Office of Ed Johnson, PLLC, Peoria By Edward D. Johnson Counsel for Appellee Child K.C. IN RE TERM OF PARENTAL RIGHTS AS TO K.C. Decision of the Court

MEMORANDUM DECISION

Judge Veronika Fabian delivered the decision of the Court, in which Presiding Judge Michael J. Brown and Vice Chief Judge David D. Weinzweig joined.

F A B I A N, Judge:

¶1 Kurt C. (“Father”) appeals the termination of his parental rights to K.C., arguing the record does not support a finding of abandonment or that termination was in the best interests of K.C. Reasonable evidence supports the court’s finding of abandonment. However, the juvenile court, in its best-interests determination, relied in large part on speculative evidence of a prospective adoption in the event of Mother’s death. This was improper under Maricopa County Juvenile Action No. JS-500274, 167 Ariz. 1 (1990). Therefore, the juvenile court’s order is vacated and remanded for further proceedings consistent with this decision.

FACTS AND PROCEDURAL HISTORY

¶2 In 2012, Shelby R. (“Mother”) and Father had one child together, K.C. After living together for two years, the parties separated and Mother filed for parenting time and child support. Father was awarded parenting time every weekend and ordered to pay child support.

¶3 In October 2017, Mother obtained a one-year order of protection against Father for herself and K.C. based on alleged physical abuse, which Father contested. Because of the order of protection, Father stopped exercising parenting time.

¶4 In June 2019, Mother moved and did not provide Father with her new address. Father moved out of Arizona in 2021 but did not tell Mother.

¶5 Although the parties disagreed as to the exact year, in either 2023 or 2024, Mother texted Father after K.C. asked to speak to his Father on K.C.’s birthday. Father then spoke to K.C. on his birthday. Otherwise, Father did not speak or physically interact with K.C. after October 2017, even though Mother testified that her email address and telephone number remained the same.

2 IN RE TERM OF PARENTAL RIGHTS AS TO K.C. Decision of the Court

¶6 In March 2025, Mother petitioned to terminate Father’s parental rights, alleging abandonment and abuse. A termination adjudication hearing was held on August 27, 2025.

¶7 Mother testified K.C. wanted Father’s parental rights terminated. K.C.’s attorney confirmed K.C. was “worried that [K.C.’s] father’s going to disrupt how well [K.C.’s] doing.” According to Mother, K.C. was well-adjusted to the community and had family in town. K.C. had also developed a close relationship with K.C.’s maternal uncle and saw him as a father figure. Based on that close relationship, Mother testified she would like maternal uncle to take custody of K.C. in the event something happened to her. Maternal uncle did not testify.

¶8 Father testified that he emailed Mother and tried to call her once he believed the order of protection expired. He also testified that Mother reached out to facilitate contact only once in 2024 and thereafter threatened to block him if he contacted her again. Paternal grandmother testified she left voicemails and texted Mother over the years. Father provided no phone records or other documentary evidence showing his phone calls.

¶9 Father, paternal grandmother, and Father’s wife also testified Father tried to modify custody many times, each time filing a petition for modification, but he could not serve Mother because her address was unknown. The court, however, took judicial notice that there was no record in the court docket of any such petitions.

¶10 On September 3, 2025, the court found clear and convincing evidence of abandonment (but not of abuse) because “[F]ather did nothing to see [K.C.] after he moved in 2021” and “Mother’s actions do not rise to the level of interference required to establish a defense to abandonment.” The court also found that termination of Father’s parental rights was in K.C.’s best interests. Father timely appealed. This Court has jurisdiction pursuant to Article VI, Section 9 of the Arizona Constitution and A.R.S. §§ 8-235(A), 12-120.21(A)(1), and 12-2101(A)(1).

DISCUSSION

¶11 Father argues the record does not support the court’s determination that he abandoned K.C. and that termination was in the best interests of K.C. A court may terminate parental rights if: (1) any ground for termination under A.R.S. § 8-533 is proven by clear and convincing evidence and (2) a preponderance of evidence supports termination would be in the child’s best interests. Kent K. v. Bobby M., 210 Ariz. 279 (2005). The

3 IN RE TERM OF PARENTAL RIGHTS AS TO K.C. Decision of the Court

best-interests finding must rely on more than speculative evidence. See JS- 500274, 167 Ariz. at 7. Under A.R.S. § 8-538(A), “[e]very order of the court terminating the parent-child relationship . . . shall be in writing and shall recite the findings on which the order is based.”

¶12 In reviewing a termination order, this Court “review[s] the factual findings made by the juvenile court, and its factual findings will be accepted ‘if reasonable evidence and inferences support them.’” Brionna J. v. Dep’t of Child Safety, 255 Ariz. 471, 478 ¶ 30 (2023) (quoting Jessie D. v. Dep’t of Child Safety, 251 Ariz. 574, 580 ¶ 10 (2021)). This Court will not reweigh reasonable evidence already considered by the juvenile court because “the juvenile court is in the best position to weigh evidence and assess witness credibility.” Id. at 478 ¶ 30 (quoting Jessie D., 251 Ariz. at 580 ¶ 10). The juvenile court’s legal conclusions “will be affirmed unless they are clearly erroneous.” Brionna J., 255 Ariz. at 479 ¶ 31.

I. Reasonable Evidence Supports the Court’s Finding of Abandonment.

¶13 Abandonment is:

[T]he failure of a parent to provide reasonable support and to maintain regular contact with the child, including providing normal supervision. Abandonment includes a judicial finding that a parent has made only minimal efforts to support and communicate with the child. Failure to maintain a normal parental relationship with the child without just cause for a period of six months constitutes prima facie evidence of abandonment.

A.R.S. § 8-531(1).

¶14 Father argues there is not clear and convincing evidence that he abandoned K.C. Specifically, he claims he “made objective—yet unsuccessful efforts” to reestablish parenting time after Mother’s order of protection expired, including: (1) attempts to modify parenting time, (2) child support payments, and (3) contact with K.C. when Mother permitted.

¶15 Reasonable evidence supports the court’s finding that Father abandoned K.C., including that Father: (1) had not seen K.C.

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In Re Term of Parental Rights as to K.C., (Ark. Ct. App. 2026).

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Related

Kent K. v. Bobby M.
110 P.3d 1013 (Arizona Supreme Court, 2005)
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304 P.3d 1115 (Court of Appeals of Arizona, 2013)