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 The unpublished decision, Mikalacki v. Mihalovich, was issued in 2026 and is available through Justia U.S. Law.The case turns on a basic but often misunderstood principle of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. But the court’s analysis focused on whether the error actually caused her to lose something she would otherwise have received.The appellate court found that she had not proven that the missing $100,000 would have…