In re the Marriage of Flores, 289 P.3d 946

Flores and Martinez divorced in 2008; dissolution decree allocated the mixed-use property (residence and restaurant) to Martinez and provided Flores with specific monetary shares.
The mixed-use property is a single parcel in Apache Junction; the decree allocated Flores $287,500 for her share of the property and $150,000 of restaurant income, then reduced totals to judgment.
Flores sought to collect the judgment by alleging Martinez fraudulently transferred the property to their daughter; trial court modified the decree in April 2011 to award Flores the mixed-use property and to award Martinez a $287,500 judgment.
Martinez moved to amend the April 27, 2011 order under Rule 84, Ariz. R. Fam. Law P.; Flores filed a notice of appeal less than an hour later.
The appellate court dismissed Flores’s prior appeal for lack of jurisdiction because the notice of appeal was filed while the Rule 84 motion was pending.
Flores then sought a fresh order denying Martinez’s motion to amend, which the trial court granted on March 18, 2012; Flores appealed again on April 6, 2012; the mandate in the prior appeal issued July 31, 2012.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Flores’s April 6, 2012 appeal is jurisdictionally improper.	Flores argues jurisdiction under A.R.S. § 12-2101(A)(1) and (A)(5).	Martinez does not dispute Flores’s asserted jurisdiction.	Appeal dismissed for lack of jurisdiction.

Davis v. Cessna Aircraft Corp., 168 Ariz. 301 (App. 1991) (court reviews its jurisdiction sua sponte; time limits for appeals must be respected)
Kim v. Mansoori, 214 Ariz. 457 (App. 2007) (notice of appeal timing affects jurisdictional analysis)
In re Marriage of Dorman, 198 Ariz. 298 (App. 2000) (criteria for appealable special orders under § 12-2101)
Haroutunian v. Valueoptions, Inc., 218 Ariz. 541 (App. 2008) (entry of judgment for purposes of determining time to file notice of appeal)