Christina G. v. Arizona Department of Economic Security
In Christina G. v. Arizona Department of Economic Security, 227 Ariz. 231, 235 n.8,15, 256 P.3d 628, 632 n.8 (App. 2011) the Court noted that a parent may waive the right to challenge on appeal the adequacy of ADES's reunification efforts by failing to raise the issue in the juvenile court proceedings.
The Court explained that the mother in that case had not "requested additional services or raised an objection to the manner in which court-ordered services were being provided, despite multiple opportunities to do so at various stages of the proceedings." Id.
The Court also noted that the mother had failed to object to the juvenile court's explicit findings "that ADES was making reasonable efforts" in providing reunification services. Id.
The Court declined to affirm the case based on waiver, however, because ADES did not raise it as an argument on appeal. Id.