Ghadimi v. Soraya, 230 Ariz. 621

Husband filed a petition for dissolution of non-eovenant marriage without children in November 2008.
The family court entered an unsigned minute-entry dissolution in July 2010 and ordered Wife to pay 65% of Husband’s fees; Husband to submit fee application.
On September 10, 2010, the family court entered a signed fifteen-page decree mirroring the minute entry but not yet fixing the exact fee amount.
Wife filed a notice of appeal on October 7, 2010.
On November 16, 2010, the court entered a signed Judgment granting Husband $275,000 in fees and costs, and directed entry of final judgment per Rule 58, with Wife not filing a new or amended notice of appeal.
This appeal was dismissed for lack of jurisdiction due to prematurity of the notice of appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Wife’s notice of appeal was premature	Wife contends finality triggered appeal rights.	Husband argues final judgment not yet entered for appeal.	Appeal dismissed for lack of jurisdiction; premature notice was ineffective.
Whether the Barassi exception applies to a premature notice of appeal	Wife seeks Barassi relief allowing premature appeal to proceed.	Barassi exception does not apply because the judgment was not final and the task was not ministerial.	Barassi exception did not apply; insufficient finality.
Whether the September 10, 2010 decree was a final judgment for appeal purposes	Decree finalized the dissolution and fees judgment should follow.	Decree did not fix the fee amount nor include Rule 78(B) finality language; not final.	Decree was not final; not appealable.
Whether the October 7, 2010 notice of appeal could become effective after a later final judgment	Premature notice could still be salvaged under limited authority.	No later final judgment to trigger Barassi; procedure invalid.	Premature notice remained ineffective; jurisdiction lacks.

Barassi v. Matison, 130 Ariz. 418 (Ariz. 1981) (premature notice of appeal requires Barassi exception to be effective)
Smith v. Ariz. Citizens Clean Elections Comm’n, 212 Ariz. 407 (Ariz. 2006) (Barassi exception limited when remaining task is ministerial)
Craig v. Craig, 227 Ariz. 105 (Ariz. 2011) (Barassi exception limited; premature notice ineffective absent ministerial task)
Stevens v. Mehagian’s Home Furnishings, Inc., 90 Ariz. 42 (Ariz. 1961) (judgment may be non-final where claims remain or discretion applies)
Pulaski v. Perkins, 127 Ariz. 216 (Ariz. 1980) (absence of Rule 54(b) language defeats finality when multiple claims remain)
Bryant v. Bryant, 40 Ariz. 519 (Ariz. 1932) (distinguishes ministerial vs. judicial acts for finality)