The Arizona Court of Appeals rejected the malpractice claim after the plaintiff failed to show actual, measurable loss resulting from her attorney's missed filing deadline. The underlying clerical error had mistakenly reduced a $200,000 loan from the client's father down to $100,000 within the divorce decree. Because the client did not prove that correcting the discrepancy would have revised the property distribution, the court affirmed that the causation standard was not met.
Key points
Professional negligence alone is insufficient to win an Arizona legal malpractice suit wi…: Professional negligence alone is insufficient to win an Arizona legal malpractice suit without measurable financial harm.
Plaintiffs must prove that an attorney's standard-of-care failure directly altered the le…: Plaintiffs must prove that an attorney's standard-of-care failure directly altered the legal outcome of their case.
Clerical errors that fail to affect the final distribution of assets cannot sustain malpr…: Clerical errors that fail to affect the final distribution of assets cannot sustain malpractice claims.
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In an Arizona divorce, a decree mistakenly listed a $200,000 loan from the wife’s father as just $100,000. Her lawyer then missed a deadline to correct the error, but the Arizona Court of Appeals, Division One, rejected her legal malpractice case because she could not prove she suffered an actual loss as a result. The unpublished decision, Mikalacki v. Mihalovich, was issued in 2026 and is available through Justia U.S. Law.
The case turns on a basic but often misunderstood principle of legal malpractice law. A client must show not only that the lawyer made a mistake, but that the mistake caused a real, measurable loss. In this case, the court found that the wife had not established that the missing $100,000 would have changed the outcome of her divorce.
What happened in the divorce
The wife, Mikalacki, was involved in a divorce where a $200,000 loan from her father was incorrectly listed in the decree as $100,000. The error was not caught in time, and her lawyer missed the deadline to correct it.
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