Hughes v. Hughes
In Hughes v. Hughes, 177 Ariz. 522, 869 P.2d 198 (App. 1993) the Court remanded an order granting indefinite spousal maintenance for redetermination because the trial court failed to provide reasons for an award of indefinite duration:
"In the absence of such an explanation, the trial court's exercise of discretion is essentially unreviewable; and we have been unable to supply the missing explanation from our independent review." Id. at 525, 869 P.2d at 201.
See generally 5 Am. Jur. 2d Appellate Review 591 (1995) ("State appellate courts have the power to remand cases for further proceedings, including a new trial, the introduction of new evidence, clarification of a lower court's ruling, . . . or entry of additional findings.")