Cited by

(“Attorney’s fees are meant to make a party whole for costs incurred for an attorney’s services.”).

tenant may recover the property and money due to the tenant together with damages in an amount equal to twice the amount wrongfully withheld.”); (explaining § 13-1321(E) “allows the tenant to recover a judgment equal to three times the amount wrongfully withheld: first, the tenant can recover the money wrongfully withheld and still due; second, the tenant is allowed to receive as damages an additional amount equal to twice the amount withheld”

§ 12- 349, where attorney fees were awarded as a sanction against defendants for pressing a groundless defense and abusing discovery.

But Moedt, and the case on which it relied, are not relevant to the issue presented here.

§ 42-18206 (“[J]udgment shall be entered in favor of the plaintiff against the person for the costs incurred by the plaintiff, including reasonable attorney fees to be determined by the court.”) (emphasis added); (“Attorney’s fees are meant to make a party whole for costs incurred for an attorney’s services.”).

[when] *368 the parties have provided in their contract the conditions under which attorney’s fees may be recovered,” , see also Geller v. Lesk, 230 Ariz, 624, 627 ¶ 9, (stating that parties’ contractual attorney fee provision, “not the statute,” governs an award of fees); , 418 n.2, , 1242 n.2 (App. 1995) (stating that “when a contract has an attorney’s fee provision it controls to the exclusion of the statute”); Connor v. Cal-Az Properties, Inc., , (stating that “§ 12-341.01 is not to be consi

Motors Corp., ¶ 11, ( ).

¶13 to support her contention that FICA’s and FIE’s obligation to pay fees was not genuine.

3 JACKSON WHITE v. DOS LAND Decision of the Court 230–32 (App. 2014) (barring the recovery of attorneys’ fees by self- represented attorneys or law firms); –20, –44 (App. 1995) (denying award of attorneys’ fees to a self- represented attorney because such an award would injure the dignity of the courts and attorneys and foster litigation over specious claims).

See Harris, 158 Ariz. at 384, 762 P.2d at 1338; n.2, n.2 (App. 1995) (contract’s attorney fees provision controls to exclusion of statute).

Opinion of the Court Attorney Fees ¶5 In Arizona, it is the rule that parties who represent themselves in a legal action are not entitled to recover attorney fees.3 -20, -44 (App. 1995); Hunt Inv.

2 ¶24 Belliard also argues that a partial retrial on punitive damages would permit the jury to award punitive damages “in the absence of an award of actual damages,” , Carter-Glogau Laboratories, Inc. v. Construction, Production & Maintenance Laborers’ Local 383, , and Fousel v. Ted Walker Mobile Homes, Inc.

418 n. 2, , 1242 n. 2 (App.1995) (“[W]hen a contract has an attorney’s fees provision it controls to the exclusion of the statute.”).

¶ 11 At least two requirements are necessary for the recovery of attorney’s fees: an attorney-client relationship between the party and counsel, and “a genuine financial obligation on the part of the litigant[ ] to pay such fees.”

Corp., , Hyatt Regency, 184 Ariz. at 131 , 907 P.2d at 517

(interpreting the “may recover” language of A.R.S.