Evans v. Evans
In Evans v. Evans, 117 Ariz. 561, 561, 574 P.2d 49, 49 (App. 1977), the Court had remanded a case to the trial court, finding it "error to modify custody without affording both parents an opportunity to present evidence of all the circumstances which might affect the court's determination of the primary question."
Although the case was specifically remanded for further proceedings in the custody matter, the Court held that "petitioner's timely request for a change of judge should have been honored." Id. at 562, 574 P.2d at 50.