Tiffany Taylor v. Thomas Pandola, 408 P.3d 1254

In August 2014 Father (Pandola) registered a 2004 Illinois child-support order in Arizona and filed a sworn registration statement asserting arrears were zero.
Mother (Taylor) — through counsel — accepted service of the registration documents in September; Father later filed a proposed judgment confirming arrears as zero through the registration date.
Mother moved in November to contest the arrears amount, but the family court held her motion untimely because it was filed more than twenty days after service and confirmed the zero-arrearage finding.
A split Arizona Court of Appeals affirmed in part and reversed in part, holding Mother could not timely contest the Illinois order’s arrears but could contest factual allegations in Father’s arrears statement.
The Arizona Supreme Court granted review to decide whether AUIFSA precludes a non-registering obligee from contesting a registering obligor’s statement of arrears when she fails to request a hearing within 20 days of notice.

Issue	Plaintiff's Argument (Taylor)	Defendant's Argument (Pandola)	Held
Whether AUIFSA bars an obligee from later contesting a registering obligor’s statement that understates arrears if she did not request a hearing within 20 days	Taylor: AUIFSA does not preclude her post-registration challenge because the statute’s listed defenses are limited and do not include an obligee’s claim that arrears were understated	Pandola: Failure to timely request a hearing precludes any contest of arrears; obligee must object within 20 days or lose the right to contest the arrearage amount	Held: AUIFSA does not bar an obligee from contesting a registering obligor’s understatement of arrears when that ground was not one of the defenses that "could have been asserted" at registration; reversed and remanded

State ex rel. DES v. Pandola, 240 Ariz. 543 (App. 2016) (Court of Appeals decision under review)
Parrot v. DaimlerChrysler Corp., 212 Ariz. 255 (statutory interpretation reviewed de novo)
Kent K. v. Bobby M., 210 Ariz. 279 (legislative intent guides statutory construction)
State v. Jurden, 239 Ariz. 526 (apply unambiguous statute as written)
de Leon v. Jenkins, 49 Cal. Rptr. 3d 145 (Cal. Ct. App. 2006) (UIFSA did not permit obligee to have objected to understatement of arrears at registration)
In re Marriage of Yuro, 192 Ariz. 568 (federal full faith and credit and treatment of monthly support payments as vested judgments)
State v. Aguilar, 209 Ariz. 40 (statutory text controls over commentary)
State v. Korzep, 165 Ariz. 490 (give statutory language its usual meaning)