Arizona appeals court rejects malpractice claim over lawyer's missed deadline in $200,000 divorce loan dispute

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 The unpublished decision, Mikalacki v.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 divorceThe 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.That kind of mistake can feel devastating, especially when it involves a large sum of money.