State v. Valentine
In State v. Valentine, 190 Ariz. 107, 945 P.2d 828 (App. 1997), an ADOC inmate challenged child support orders entered after a hearing in his absence in a paternity case. 190 Ariz. at 109, 945 P.2d at 830.
In ordering a new hearing, one in which the inmate could appear from the prison by telephone, id. at 111, 945 P.2d at 832, the court stated that "transportation and security costs relating to Valentine's participation in the telephonic hearing must be borne by ADOC, just as they would be if Valentine were physically transported to the court to participate in person." Id. at 112, 945 P.2d at 833.