Jesus M. v. Arizona Department of Economic Security
In Jesus M. v. Arizona Department of Economic Security, 203 Ariz. 278, 53 P.3d 203 (Ariz. Ct. App. 2002), the court rejected a forward-looking construction of an analogous provision which would have measured the starting point from the decision on termination.
The court stated that "what matters to a dependent child is the total length of time the parent is absent from the family, not the more random time that may elapse between the conclusion of legal proceedings for severance and the parent's release from prison." Id. at 206.