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UNDER ARIZONA RULE OF THE SUPREME COURT 111(c), THIS DECISION IS NOT PRECEDENTIAL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

JEFFREY STROBEL, Petitioner/Appellee,

v.

GAIL ROSIER, Respondent/Appellant,

__________________________________

STATE OF ARIZONA, ex rel., DEPARTMENT OF 

ECONOMIC SECURITY, Intervenor/Appellee.

No. 1 CA-CV 16-0644 FC

Appeal from the Superior Court in Maricopa County

No. FC2012-001202

The Honorable Paul J. McMurdie, Judge

AFFIRMED

COUNSEL

Baskin Richards PLC, Phoenix

By William A. Richards, David E. Wood

Counsel for Petitioner/Appellee

Horne Law PLLC, Phoenix

By Mark W. Horne

Counsel for Respondent/Appellant

FILED 10-18-2018
STROBEL, et al. v. ROSIER

Decision of the Court

2

MEMORANDUM DECISION

Presiding Judge Michael J. Brown delivered the decision of the Court, in 

which Judge Jennifer B. Campbell and Chief Judge Samuel A. Thumma

joined.

B R O W N, Judge:

¶1 Gail Rosier (“Mother”) challenges the superior court’s ruling 

confirming the validity of a registered order enforcing New Hampshire 

child support arrearage orders. For the following reasons, we affirm.

BACKGROUND

¶2 Jeffrey Strobel (“Father”) obtained child support arrearage 

orders in New Hampshire, where he lives with the parties’ now adult child. 

Father sought to enforce the New Hampshire orders in Arizona. In early 

2012, the Arizona Department of Economic Security (“ADES”) filed a notice 

of registration and petition to enforce support, asking the superior court to 

enter a judgment against Mother for $202,500 for past due child support.

The New Hampshire orders in question are the product of a complicated 

procedural dispute, summarized as follows.

¶3 The parties’ marriage was dissolved in 1996 pursuant to a 

Dominican Republic divorce decree that did not include an order for child 

support. In 2006, Father and the child lived in New Hampshire, and Mother 

lived in Arizona. Mother filed a petition to register the divorce decree in 

New Hampshire and establish a parenting plan, which resulted in a July 

2006 order registering the decree and establishing long-distance visitation.

This order did not include any child support provisions. 

¶4 In 2008, Father filed a motion to clarify, which essentially 

requested a child support order. Father alleged the parties agreed in 1997 

that Mother would save for college instead of paying child support, and in 

the 2006 proceedings, she admitted in her financial affidavit that she held 

an interest in real property valued at $150,000 for that specific purpose.1 As 

 

1 Later, Mother asserted she made a clerical error in her financial 

affidavit, and that the value of her interest in the real property was actually

$105,000. 
STROBEL, et al. v. ROSIER

Decision of the Court

3

a result, the New Hampshire court entered an order in March 2009 (“March 

2009 Order”) directing Mother to immediately liquidate the real property

being held for the child’s education expenses and place the funds in an 

appropriate account. The court stated that although there had never been 

a child support order entered, it specifically considered and found it had 

jurisdiction over Mother “to establish, enforce, or modify a support order 

pursuant to [New Hampshire Revised Statutes Annotated (“R.S.A.”)

section] 546-B:3 II, III, and IV,” and that the parties’ 1997 agreement was 

valid and enforceable. Mother was not present at the hearing and the court 

found she was in default. 

¶5 When Mother failed to provide an accounting as ordered, 

Father filed a petition for contempt in July 2009, asking the New Hampshire 

court to enter an order specifying that Mother owed $105,000 in past child 

support. In a letter to the court dated December 8, 2009, Mother stated she 

was incarcerated in Arizona and could not appear at the contempt hearing 

set for December 22, 2009, until after she was released and received

permission to travel from her parole officer. On December 22, 2009, the 

court granted Mother’s request and continued the hearing to March 9, 2010. 

However, the court also granted Father’s proposed order “on an ex parte 

basis” and found Mother in contempt of the March 2009 Order to pay child 

support.

¶6 In a subsequent letter, Mother informed the New Hampshire 

court she could not afford to attend the March 9, 2010 hearing and asked to 

appear telephonically. Mother also stated her late husband’s assets were 

subject to probate litigation and she could not liquidate the real property. 

¶7 On March 9, 2010, the New Hampshire court entered an order 

(“2010 Arrearage Order”) finding Mother in contempt for failing to pay 

child support and ordered an immediate payment of $25,000. The court 

found Mother owed $202,500 in child support arrearages plus interest and 

ordered Mother to reimburse Father for a $7,500 inheritance her late 

husband left for the child that “she spent.” The 2010 Arrearage Order 

included a payment schedule indicating Mother owed $105,000 in back 

child support as of March 1, 2010, payable immediately or pursuant to a

payment schedule that added $10,000 a year, up to and including March 1, 

2020 for a total of $205,000 in back child support. The New Hampshire 

court issued a corresponding Uniform Support Order (“USO”) for child 
STROBEL, et al. v. ROSIER

Decision of the Court

4

support arrearages of $202,500 as of October 31, 2009, which included the 

payment schedule.2

¶8 Shortly thereafter, Father moved to clarify the USO to require 

that Mother make consistent monthly payments. In June 2010, the New 

Hampshire court issued an amended USO (“June 2010 USO”) ordering

Mother to pay child support arrearages of $202,500 at the rate of $10,000 per 

month. The June 2010 USO did not include the payment schedule attached 

to Father’s motion to clarify.

¶9 Father, with the assistance of ADES, sought to enforce the 

June 2010 USO in Arizona. In response to the Arizona petition to enforce, 

Mother claimed the New Hampshire orders were issued ex parte, in 

violation of her due process rights and without any legal basis. Mother 

admitted she was served with unspecified papers regarding the New 

Hampshire motions while incarcerated but stated she was in no position to 

respond financially or emotionally. Mother informed the Arizona court 

that a hearing on her motion to vacate the New Hampshire orders was 

pending, which resulted in a continuance of the hearing in Arizona pending 

a resolution of Mother’s New Hampshire motion to vacate. 

¶10 In May 2014, after briefing and oral argument, the New 

Hampshire court found no basis for vacating the existing orders, 

concluding that the June 2010 USO “is an enforceable order on a child 

support arrearage.” The New Hampshire Supreme Court declined 

Mother’s notice of appeal.

3

¶11 Back in Arizona, Mother raised several defenses to 

enforcement pursuant to Arizona Revised Statutes (“A.R.S.”) section 

25-1307 and the Full Faith and Credit for Child Support Orders Act, 28 

United States Code (“U.S.C.”) section 1738B. ADES took no position on 

Mother’s request to vacate the registration or enforcement. Father argued 

Mother was precluded from seeking relief from enforcement under the 

 

2 Mother claimed she first received the 2010 Arrearage Order on 

November 11, 2013, after appearing in court in Arizona.

3 As the New Hampshire Supreme Court explained, pursuant to “Rule 

7(1)(B), the supreme court may decline to accept a notice of discretionary 

appeal from the superior or circuit court. No appeal, however, is declined 

except by unanimous vote of the court with at least three justices 

participating.” 
STROBEL, et al. v. ROSIER

Decision of the Court

5

doctrines of res judicata, the Full Faith and Credit Clause of the United 

States Constitution, and 28 U.S.C. § 1738B.

¶12 After an evidentiary hearing, the Arizona superior court 

found Mother failed to establish a defense to enforcement under A.R.S. 

§ 25-1307(A) and confirmed the registration of the New Hampshire 

arrearage orders. We have jurisdiction over Mother’s timely appeal 

pursuant to A.R.S. § 12-2101(A)(1).

DISCUSSION

¶13 To contest the validity or enforcement of the New Hampshire 

orders, Mother has the burden of proving the orders were not entitled to 

full faith and credit or establishing one of the defenses recognized in A.R.S. 

§ 25-1307(A), which is part of Arizona’s version of the Uniform Interstate 

Family Support Act. Judgments rendered in a particular state shall be given 

the same full faith and credit by the courts of every other state “as the 

judgment would be accorded in the rendering state.” Phares v. Nutter, 125 

Ariz. 291, 293 (1980). “But foreign judgments may be attacked if the 

rendering court lacked jurisdiction over the person or subject matter, the 

judgment was obtained through lack of due process, the judgment was the 

result of extrinsic fraud, or if the judgment was invalid or unenforceable.” 

Id. Whether a foreign judgment is entitled to full faith and credit is a 

question of law that we review de novo. Grynberg v. Shaffer, 216 Ariz. 256, 

257, ¶ 5 (App. 2007). 

A. Subject Matter Jurisdiction 

¶14 Pursuant to 28 U.S.C. § 1738B(c)(1)(A), a foreign support 

order is entitled to full faith and credit if the issuing court had subject matter 

jurisdiction to hear the matter and enter the order and had personal 

jurisdiction over the parties. “[A] duly authenticated judgment of a court 

of general jurisdiction of a sister state is prima facie evidence of that court’s 

jurisdiction to render it and of the right which it purports to adjudicate.” 

Lofts v. Superior Court, 140 Ariz. 407, 411 (1984). Mother asserts the New 

Hampshire court did not have subject matter jurisdiction (1) to enforce the 

agreement to pay college expenses as a child support order, or (2) to enter 

an arrearage order when there was no prior child support order. 

¶15 Mother characterizes these arguments as challenges to the 

New Hampshire court’s subject matter jurisdiction; however, her

arguments are based on the correctness of the rulings under applicable New 

Hampshire law. Subject matter jurisdiction “refers to a court’s statutory or 

constitutional power to hear and determine a particular case.” In re 
STROBEL, et al. v. ROSIER

Decision of the Court

6

Marriage of Thorn, 235 Ariz. 216, 220, ¶ 17 (App. 2014) (quoting State v. 

Maldonado, 223 Ariz. 309, 311, ¶ 14 (2010)). Allegations of legal error do not 

constitute a lack of subject matter jurisdiction. In Estes v. Superior Court, our 

supreme court “distinguished ’the right of a court to misconstrue the law 

measuring the rights of the parties . . . [from] the right of a court to 

misconstrue a statute or law from which jurisdiction or power of the court 

flows—a jurisdictional law.’” Estes v. Superior Court, 137 Ariz. 515, 517 

(1983) (quoting Ariz. Pub. Serv. Co. v. S. Union Gas Co., 76 Ariz. 373, 382

(1954)). “Misinterpreting a procedural matter amounts to legal error which 

may result in reversal by an appellate court, but subject matter jurisdiction 

remains unaffected by the misinterpretation.” Id. Allegations that the New 

Hampshire orders were improperly based on a contract, instead of child 

support guidelines, and were not based on a prior child support order,

constitute assertions of legal error, not a lack of subject matter jurisdiction.

¶16 Even assuming Mother is challenging more than the 

correctness of the New Hampshire court’s rulings, she has failed to 

establish that the arrearage orders are void for lack of subject matter 

jurisdiction. Relying on In re Goulart, 965 A.2d 1068, 1071 (N.H. 2009), 

Mother argues that “New Hampshire courts are without subject matter 

jurisdiction to issue or enforce any order for the payment of college 

expenses.” In Goulart, the parents stipulated to inclusion of a provision for 

payment of college expenses in the anticipated divorce decree, 

notwithstanding a statutory provision that prohibited such an order. Id. at 

1070 (citing R.S.A. 461–A:14, V (“No child support order shall require a 

parent to contribute to an adult child's college expenses or other 

educational expenses beyond the completion of high school.”)). The New 

Hampshire Supreme Court held that the family court lacked subject matter 

jurisdiction to approve a parenting plan or issue an order requiring a parent 

to pay an adult child's college education expenses and a parent’s “’waiver’ 

could not confer subject matter jurisdiction where it did not exist; and any 

such orders were void.” Id. at 1071. The New Hampshire arrearage orders 

in this case, although based on the parties’ 1997 agreement, do not require 

Mother to contribute to her son’s “college expenses or other educational 

expenses” and thus the orders do not fall within the plain language of the 

statute at issue in Goulart. See id. at 1070 (citing R.S.A. 461–A:14, V). 

¶17 Moreover, Mother fails to acknowledge the “proposition that 

the requirements of full faith and credit bar a defendant from collaterally 

attacking a divorce decree on jurisdictional grounds in the courts of a sister 

State where there has been participation by the defendant in the divorce 

proceedings, where the defendant has been accorded full opportunity to 

contest the jurisdictional issues, and where the decree is not susceptible to 
STROBEL, et al. v. ROSIER

Decision of the Court

7

such collateral attack in the courts of the State which rendered the decree.” 

Sherrer v. Sherrer, 334 U.S. 343, 351–52 (1948); see also Williams v. North 

Carolina, 325 U.S. 226, 230 (1945) (“It is one thing to reopen an issue that has 

been settled after appropriate opportunity to present their contentions has 

been afforded to all who had an interest in its adjudication. This applies also 

to jurisdictional questions. After a contest these cannot be relitigated as 

between the parties.”).

¶18 Mother had a full opportunity to challenge the New 

Hampshire court’s subject matter jurisdiction but did not do so until Father 

registered the arrearage orders in Arizona. In fact, Mother indicated just 

the opposite when she filed her 2014 motion to vacate in New Hampshire, 

stating that “[she] does not dispute that the Court had jurisdiction to 

establish a child support order under the Uniform Interstate Family 

Support Act, [R.S.A.] chapter 546-B:31.” Thus, Mother has failed to meet 

her burden of showing that the New Hampshire court lacked subject matter 

jurisdiction to issue the arrearage orders. 

B. Res Judicata

¶19 Mother’s collateral attacks on the merits of the New 

Hampshire orders are precluded under the doctrine of res judicata (claim 

preclusion), which provides that an existing final judgment on the merits 

by a court of competent jurisdiction bars further litigation between the same 

parties on every point decided as well as every point that could have been 

decided on the record in the prior proceeding. See Underwriters Nat’l 

Assurance Co. v. N.C. Life & Accident & Health Ins. Guar. Ass’n, 455 U.S. 691, 

710 (1982) (“A party cannot escape the requirements of full faith and credit 

or res judicata by asserting its own failure to raise matters clearly within the 

scope of a prior proceeding.”); Pettit v. Pettit, 218 Ariz. 529, 530, ¶ 1 (App. 

2008) (holding that res judicata bars re-litigation of matters actually 

litigated in a prior action as well as issues that might have been litigated); 

see also Brooks v. Trs. of Dartmouth Coll., 20 A.3d 890, 894 (N.H. 2011) (same).

¶20 Mother argues the 2010 Arrearage Order and subsequent 

New Hampshire orders were based on Father’s fraudulent 

misrepresentations in the March 2010 hearing. Mother’s allegations of legal 

errors and fraud were either raised or could have been raised in the 2014 

New Hampshire proceedings or earlier. In seeking to vacate the March 

2009 Order and subsequent orders, Mother argued in part there was no 

basis in fact or law for the New Hampshire orders. And as her counsel 

acknowledged at the Arizona evidentiary hearing, Mother could have 
STROBEL, et al. v. ROSIER

Decision of the Court

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raised all of her substantive claims, including fraud, in her 2014 New 

Hampshire motion to vacate, but she failed to do so. 

¶21 Mother contends the New Hampshire orders do not have 

preclusive effect because they were entered by default, citing Schilz v. 

Superior Court, 144 Ariz. 65 (1985). In that case, our supreme court held that 

a foreign judgment was not entitled to full faith and credit because neither 

the father nor his counsel had appeared or otherwise litigated the matters 

at issue. Schilz, 144 Ariz. at 68. Thus, the Arizona courts could consider 

whether the issuing court properly exercised jurisdiction. Id. Here, 

although Mother did not contest jurisdiction in New Hampshire, she 

appeared, or had the opportunity to appear, in those proceedings and thus 

had the opportunity to raise defenses and objections, including lack of 

jurisdiction. Accordingly, the New Hampshire orders are entitled to res 

judicata effect. See Lofts, 140 Ariz. at 411 (“When the rendering court in a 

contested hearing determines it has jurisdiction, its determination is res 

judicata on the jurisdictional issue and cannot be relitigated in another 

state.”). As to Mother’s non-jurisdictional arguments, a “default judgment 

has the same res judicata effect as a judgment in a matter where the issues 

were litigated.” Norriega v. Machado, 179 Ariz. 348, 353 (App. 1994) (citing 

Tech. Air Prods., Inc. v. Sheridan-Gray, Inc., 103 Ariz. 450, 452 (1968)). 

¶22 Mother relies on State ex rel. Dep’t of Econ. Sec. v. Powers, 184 

Ariz. 235 (App. 1995), which is also distinguishable. In Powers, the parties’ 

default divorce decree did not mention any children common to the parties. 

Id. at 237–38. In addressing a subsequent paternity action, we concluded 

that the child’s paternity was not actually litigated in the divorce 

proceeding and thus we declined to apply collateral estoppel (issue 

preclusion). Id. at 238. The analysis in Powers did not involve application 

of res judicata and thus it is not relevant to the issues presented here. Unlike 

collateral estoppel, res judicata does not require actual litigation. See Circle 

K Corp. v. Indus. Comm’n, 179 Ariz. 422, 427 (App. 1993) (“Issue preclusion 

does not apply in this case because the issue of causation has never been 

litigated.”); see also In re the Gen. Adjudication of All Rights to Use Water in the 

Gila River Sys. & Source, 212 Ariz. 64, 70 n.8, ¶ 14 (2006) (noting that only 

“claim preclusion” was at issue and recognizing that with respect to a 

default judgment, “none of the issues is actually litigated.”).

¶23 Mother never appealed the 2009 New Hampshire orders, and 

they became final. Her attempt to vacate those orders in 2014 was 

unsuccessful. She argues the 2014 New Hampshire proceedings are not 

entitled to res judicata effect because the issues raised were not actually 

litigated. However, in her motion to vacate and at the 2014 hearing, Mother 
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Decision of the Court

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argued there was no child support order on which to base an arrearages 

order; the amount of the arrearages had no factual basis; she could not 

liquidate the real property and thus could not be found in willful violation 

of a court order; and she was wrongfully denied a continuance or 

telephonic appearance. The New Hampshire court affirmed the prior

orders, and Mother’s subsequent appeal was denied. Regardless of 

whether the New Hampshire courts decided these issues correctly in 2009, 

2010, and again in 2014, the doctrine of res judicata precludes Mother from 

challenging those orders in this proceeding.4

C. Due Process

¶24 Mother also argues the New Hampshire orders are not 

entitled to full faith and credit because she was denied due process. See 28 

U.S.C. § 1738B(c)(2). She contends she was never served with the December 

2009 order, the 2010 Arrearage Order, Father’s May 2010 motion to clarify, 

or the resulting June 2010 USO. However, Father’s 2010 motion to clarify 

included a certificate of service signed by his attorney. The June 2010 USO 

states it was issued after a hearing and lists Mother’s Church Road address. 

Mother now claims the Church Road address was incorrect and that she 

notified the New Hampshire court to send everything to her criminal 

defense attorney in Arizona. But Mother’s December 8, 2009 letter to the 

court does not list an Arizona address or give her criminal defense 

attorney’s address. Similarly, Mother’s letter asking to continue the March 

9, 2010 hearing does not provide a criminal defense attorney’s address, and 

although it includes a different address under her signature, the letter does

not constitute proper notification of a change of address. 

¶25 Additionally, at the 2014 hearing in New Hampshire, Mother 

stated she received the “2010 order” and “contacted her New Hampshire 

attorney.” In the 2014 New Hampshire proceedings, Mother never claimed 

she was not served or did not receive any orders. This is inconsistent with 

her claim in the Arizona proceedings that she was not aware of the 2010 

Arrearage Order until November 2013. In light of these facts and Mother’s

letters to the New Hampshire court in December 2009 and March 2010, we 

can reasonably infer that the Arizona court found Mother’s claim that she 

was unaware of the New Hampshire orders or the status of the arrearage 

litigation was not credible. See Wippman v. Rowe, 24 Ariz. App. 522, 525 

 

4 Because we conclude the New Hampshire orders are entitled to full 

faith and credit, we need not address Father’s argument that Mother’s 

unsuccessful litigation against Father in federal district court also precludes 

Mother’s challenge to the New Hampshire orders. 
STROBEL, et al. v. ROSIER

Decision of the Court

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(1975) (holding that an appellate court “may infer from any judgment the 

findings necessary to sustain it if such additional findings do not conflict 

with express findings and are reasonably supported by the evidence”).

¶26 Mother also contends she was denied due process by the New 

Hampshire court’s denial of her request to appear telephonically and to 

appoint counsel. Regarding appointment of counsel, Mother does not point

or direct us to any part of the record where she made such a request in the 

New Hampshire court proceedings. Thus, we reject Mother’s contention 

that she was denied due process when the New Hampshire court failed to 

sua sponte appoint counsel. Moreover, a trial court may appoint counsel in 

child support enforcement cases when the possibility of incarceration exists 

and when the defendant may be treated unfairly without the assistance of 

counsel. Duval v. Duval, 322 A.2d 1, 4 (N.H. 1974). Mother has failed to 

establish how she would have been treated unfairly if she had appeared on 

her own behalf in New Hampshire in connection with the 2009 and 2010 

proceedings.

¶27 The reasons for the New Hampshire court’s failure to rule on 

Mother’s informal request to appear telephonically at the hearing are

unclear. The New Hampshire court continued the December 2009 hearing, 

thus implicitly denying the request, but in the same order it found Mother 

in contempt. The 2010 Arrearage Order was entered after Mother sent 

another letter stating she was available to appear telephonically or was 

“open to continuing the matter.” Father claimed he received Mother’s letter 

one day before the March 2010 hearing. Mother did not establish when the 

New Hampshire court received her letter. Without such evidence, the New 

Hampshire court properly may have deemed Mother’s request untimely or 

improperly filed. Mother also raised this issue in the 2014 New Hampshire

motion to vacate, which was denied. Although the ex parte/default nature 

of the December 2009 and June 2010 orders seems unusual, we cannot 

conclude on this record that Mother was deprived of due process.

D. Application of A.R.S. § 25-1307(A)

¶28 Under A.R.S. § 25-1307(A)(5), a party may seek to vacate the 

registration of a foreign support order if he or she establishes “a defense 

under the law of this state to the remedy sought.” That section provides as 

follows: 

A party contesting the validity or enforcement of a registered 

support order or seeking to vacate the registration has the 

burden of proving one or more of the following defenses: 
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Decision of the Court

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1. The issuing tribunal lacked personal jurisdiction over the 

contesting party.

2. The order was obtained by fraud.

3. The order has been vacated, suspended or modified by a 

later order.

4. The issuing tribunal has stayed the order pending appeal.

5. There is a defense under the law of this state to the 

remedy sought.

6. Full or partial payment has been made.

7. The statute of limitations applicable under § 25-1304 

precludes enforcement of some or all of the alleged 

arrearages.

8. The alleged controlling order is not the controlling order. 

A.R.S. § 25-1307(A). Mother contends her obligation to pay college 

expenses is not child support, but instead is a contractual obligation which 

cannot be enforced by way of contempt in Arizona after the child turns 18. 

In Solomon v. Findley, 167 Ariz. 409, 411–12 (1991), our supreme court held 

that the superior court lacked authority to enforce child support provisions 

after a child reached majority, but the parties’ agreement to pay college 

expenses was enforceable as an independent contract claim.

¶29 Mother contends she could not have raised this Arizona 

defense in the New Hampshire proceedings; therefore, it is not barred by 

res judicata. However, her attempt to challenge the authority to enter a 

child support order that arguably should have been handled as a contract 

claim constitutes an impermissible collateral attack on the New Hampshire 

arrearage order. Correctly or incorrectly, the New Hampshire court 

expressly concluded that the parties’ agreement supported a valid and 

enforceable child support order. After Mother failed to comply with that 

order, the New Hampshire court found her in contempt and entered a child 

support arrearage order. Mother improperly seeks to apply Arizona law 

regarding agreements to pay college expenses to an issue already decided 

by the New Hampshire court based on New Hampshire law.5

 

5 New Hampshire does allow contempt enforcement in some 

circumstances. See Solomon, 167 Ariz. at 411–12 n.2 (citing Lund v. Lund, 74 

A.2d 557, 559 (N.H. 1950) (allowing contempt action for spouse’s failure to 

pay tuition expenses of the parties’ child after she turned 18, as one of 
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Decision of the Court

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¶30 Because Mother challenges the interpretation of the arrearage

order as a child support order, the law of the issuing state applies. See 28 

U.S.C. § 1738B(h)(2). This is not an issue of enforcement, where Arizona 

law would apply. See id. § 1738B(h)(1). On this choice of law question, 28 

U.S.C. § 1738B governs and “preempts all similar state laws pursuant to the 

Supremacy Clause of the United States Constitution.” In re Marriage of Yuro,

192 Ariz. 568, 571, ¶ 7 (App. 1998). Pursuant to 28 U.S.C. § 1738B(h), we 

apply New Hampshire law to interpret the orders, not Arizona law. 

Mother, therefore, cannot rely on Solomon in her effort to challenge the 

correctness of the arrearage orders issued by the New Hampshire court. 

CONCLUSION

¶31 We affirm the order to enforce the arrearage orders. We deny 

Father’s request for an award of attorneys’ fees on appeal because he failed 

to cite any authority to support his request. See Ezell v. Quon, 224 Ariz. 532, 

539, ¶ 31 (App. 2010); see also Arizona Rules of Civil Appellate Procedure 

(“ARCAP”) 21(a)(2).

 

several jurisdictions allowing post-majority support provisions to be 

enforced by contempt)).