In Re the Marriage of Kassa, 231 Ariz. 592

Dissolution of marriage occurred in December 2006.
September 2011 Kazumi filed post-decree petition seeking contempt, increased/extended spousal maintenance, arrearages, child support modification, and attorney fees.
Trial court denied contempt and granted arrearages; on May 22, 2012 granted continuing spousal maintenance but denied increase.
Court set hearings on unresolved issues; Scott filed a notice of appeal on June 5, 2012 regarding the May 22 ruling.
Court found no jurisdiction because the post-decree petition involves multiple claims and the order was not a final, appealable judgment under Rule 78(B); notice of appeal premature.
Court denied Kazumi’s request for attorney fees due to lack of statutory/contractual basis and dismissed the appeal for lack of jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court has jurisdiction over the May 22, 2012 order	Scott argues the ruling is appealable	Kazumi’s position is not explicitly stated in the text for this issue	Appeal dismissed for lack of jurisdiction; order not final; notice premature

Sorensen v. Farmers Ins. Co. of Ariz., 191 Ariz. 464 (App. 1997) (independent duty to determine jurisdiction; review limited to statute)
Hall Family Props., Ltd. v. Gosnell Dev. Corp., 185 Ariz. 382 (App. 1995) (authority over finality and post-judgment review)
Craig v. Craig, 227 Ariz. 105 (2011) (prematurity and nullity of premature notices of appeal)
Maria v. Najera, 222 Ariz. 306 (App. 2009) (final judgment requires proper Rule 78(B) language)
In re Marriage of Dorman, 198 Ariz. 298 (App. 2000) (special order appealable when it resolves all issues)
Fields v. Oates, 230 Ariz. 411 (App. 2012) (judgment not final without Rule 54(b) certification)