Crook v. Crook

── Crook v. Crook ── Case No.: 1 CA-CV 25-0702 FC Court: Court of Appeals of Arizona Date: March 19, 2026 Category: General 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 UNDER ARIZONA RULE OF THE SUPREME COURT 111(c), THIS DECISION IS NOT PRECEDENTIAL AND MAY BE CITED ONLY AS AUTHORIZED BY RULE.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: ROBERT MATTHEW CROOK, Petitioner/Appellant, v. JIANETTE ALICIA CROOK, Respondent/Appellee. No. 1 CA-CV 25-0702 FC FILED 03-19-2026 Appeal from the Superior Court in Maricopa County No. FC2024-090167 The Honorable Charlene D. Jackson, Judge VACATED IN PART AND REMANDED COUNSEL Robert Matthew Crook, Chula Vista, CA Petitioner/Appellant MEMORANDUM DECISION Presiding Judge Daniel J. Kiley delivered the decision of the Court, in which Judge D. Steven Williams and Judge Cynthia J. Bailey joined.  CROOK v. CROOK Decision of the Court K I L E Y, Judge: ¶1 Robert Matthew Crook (“Father”) appeals from the portion of the superior court’s judgment awarding retroactive child support of $23,069 to his ex-spouse, Jianette Alicia Crook (“Mother”). For the following reasons, we vacate that portion of the judgment and remand for further proceedings. FACTS AND PROCEDURAL HISTORY ¶2 In 2013, a Colorado court issued a decree (the “Decree”) dissolving the parties’ marriage. At the same time, the court approved a parenting plan (the “Parenting Plan”) that provided in part that the parties’ two minor children would reside primarily with Mother during the school year and primarily with Father during the summer. The Parenting Plan ordered Father to pay monthly child support “directly” to Mother in accordance with a “previously issued” order. The Parenting Plan did not, however, set forth the amount of Father’s monthly child support obligation. ¶3 Mother later moved to Arizona with the children, while Father moved to California. ¶4 In January 2024, Mother filed a request with the Maricopa County Superior Court to register the Decree and the Parenting Plan under A.R.S. § 25-1055. The court granted Mother’s request. Shortly thereafter, Mother petitioned to modify the Parenting Plan to reduce Father’s court- ordered parenting time. In February 2024, Mother’s petition to modify was served on Father, who filed a response in opposition and requested affirmative relief of his own. The matter was set for an evidentiary hearing. ¶5 In a prehearing statement, Mother asked that Father be ordered to pay monthly child support of $1,357. ¶6 After the hearing, the superior court issued a ruling in July 2025 that largely affirmed the existing parenting time schedule, with certain exceptions not relevant here. The court granted Mother’s request for an award of monthly child support of $1,357, with payments due on the first day of the month beginning August 1, 2025. Without making any findings about Father’s payment of child support during the modification proceedings, the court also awarded Mother a judgment in the amount of $23,069 representing child support of $1,357 for each of the seventeen months from March 2024 (following service of Mother’s petition to modify in February 2024) through July 2025. 2  CROOK v. CROOK Decision of the Court ¶7 Father timely appealed. We have jurisdiction under A.R.S. § 12-2101(A)(1). DISCUSSION ¶8 Father does not challenge the superior court’s order requiring him to pay child support of $1,357 per month. He argues, howe