Kimminau Law Firm, P.C. v. Melody Hoopes

CourtCourt of Appeals of Arizona
DecidedJuly 13, 2026
Docket2 CA-CV 2025-0248
StatusPublished

This text of Kimminau Law Firm, P.C. v. Melody Hoopes (Kimminau Law Firm, P.C. v. Melody Hoopes) is published on Counsel Stack Legal Research, covering Court of Appeals of Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kimminau Law Firm, P.C. v. Melody Hoopes, (Ark. Ct. App. 2026).

Opinion

IN THE ARIZONA COURT OF APPEALS DIVISION TWO

KIMMINAU LAW FIRM, P.C., Plaintiff/Appellant/Cross-Appellee,

v.

MELODY HOOPES, Defendant/Appellee/Cross-Appellant.

No. 2 CA-CV 2025-0248 Filed July 13, 2026

Appeal from the Superior Court in Pima County No. C20202695 The Honorable Wayne E. Yehling, Judge

AFFIRMED

COUNSEL

Kimminau Law Firm P.C., Tucson By Chris J. Kimminau Counsel for Plaintiff/Appellant/Cross-Appellee

Mesch Clark Rothschild, Tucson By Nathan S. Rothschild and Andrew Richards Counsel for Defendant/Appellee/Cross-Appellant KIMMINAU LAW FIRM, P.C. v. HOOPES Opinion of the Court

OPINION

Vice Chief Judge Eppich authored the opinion of the Court, in which Presiding Judge Vásquez and Chief Judge Staring concurred.

E P P I C H, Vice Chief Judge:

¶1 This appeal arises from a retainer fee agreement entered into by Melody Hoopes with Kimminau Law Firm, P.C. (“Kimminau”) to represent her in her dissolution of marriage proceedings. The issues presented in this contract case are whether Arizona law and substantial evidence support Hoopes’s defense of equitable recoupment, whether she was entitled to a jury trial, whether the trial court gave proper jury instructions, whether the court erred by denying Kimminau’s motion for a new trial, and whether the court erred by awarding Hoopes her attorney fees. For the following reasons, we affirm.

Factual and Procedural Background

¶2 “We view the facts in the light most favorable to upholding the judgment.” Paz v. City of Tucson, 256 Ariz. 391, ¶ 2 (App. 2023). Hoopes hired Kimminau to represent her in her dissolution of marriage proceedings in 2015. During that representation, Kimminau failed to request Hoopes’s share of her former husband’s pension under Koelsch v. Koelsch, 148 Ariz. 176 (1986), until almost a year after receiving the necessary disclosure, and months after the parties had already settled. A year later, Hoopes fired Kimminau and hired another attorney. Kimminau then sent Hoopes an invoice for services rendered between the time he requested Hoopes’s share of the pension and his firing, which Hoopes did not pay.

¶3 In June 2020, Kimminau sued Hoopes for the unpaid invoice, alleging breach of contract and seeking damages of $19,304.81 plus interest. Hoopes admitted she had entered a contract with Kimminau but disputed the balance owed, claiming she did not receive “legal services” as contemplated by the contract, there was not adequate consideration to justify the fee requested, and several affirmative defenses, including equitable recoupment. Kimminau moved for summary judgment, contending Hoopes’s allegations of legal malpractice could not be a defense to a breach of contract claim unless “there is a specific promise in the contract” that he violated through professional malpractice. The court

2 KIMMINAU LAW FIRM, P.C. v. HOOPES Opinion of the Court

denied the motion, finding questions of fact existed as to whether Kimminau fully performed under the contract and the value of any services provided. After trial, a jury found Kimminau did not prove that Hoopes had breached the contract. The court awarded Hoopes her attorney fees and costs.

¶4 Kimminau appealed, and this court vacated the jury’s verdict concluding that, as a matter of law, “Kimminau’s allegedly incompetent performance d[id] not constitute a breach of the fee agreement between the parties” thus Hoopes’s “failure of consideration defense fail[ed].” Kimminau Law Firm, P.C. v. Hoopes, No. 2 CA-CV 2022-0005, ¶ 17 (Ariz. App. May 10, 2023) (mem. decision). However, this court determined that the trial court did not err by denying Kimminau’s motion for summary judgment on Hoopes’s equitable recoupment defense. Id. ¶ 18. Because the jury appeared to have returned its verdict based on the failure of consideration, this court ordered the trial court to grant Kimminau’s motion for summary judgment as to the breach of contract issue but remanded the case for Hoopes to litigate her equitable recoupment defense. Id. ¶¶ 17-18, 27.

¶5 More than six months after this court issued its mandate, Kimminau filed a motion for entry of judgment with the trial court, which the court denied. The court then granted Kimminau partial summary judgment on his breach of contract claim and the damages owed. The court also found that Hoopes was entitled to a jury trial on her affirmative defense of recoupment, which, if successful, would reduce up to, but not exceeding, the amount owed to Kimminau for damages. After trial, the jury found Hoopes entitled to equitable recoupment of $30,156.93 against the $19,304.81 owed to Kimminau. Kimminau filed a motion for a new trial, claiming the verdict was not supported by the evidence and the court had erred by denying a jury instruction. The court denied the motion and, upon Hoopes’s motion, awarded Hoopes her attorney fees and costs pursuant to A.R.S. §§ 12-332, 12-341, and 12-341.01. Kimminau appealed, and we have jurisdiction pursuant to article VI, § 9 of the Arizona Constitution and A.R.S. §§ 12-2101(A)(1), (A)(2) and 12-120.21.1

1Hoopes filed a cross-appeal. However, given our disposition, we need not address it. See Progressive Specialty Ins. Co. v. Farmers Ins. Co. of Ariz., 143 Ariz. 547, 548 (App. 1985) (appellate court should not “decide issues unless it is required to do so in order to dispose of the appeal under consideration”).

3 KIMMINAU LAW FIRM, P.C. v. HOOPES Opinion of the Court

Discussion

I. Judgment as a Matter of Law

¶6 Kimminau asserts the trial court erred by denying his motion for judgment as a matter of law (JMOL). We review the denial of a motion for JMOL de novo, but we view the evidence in the light most favorable to Hoopes. See Dupray v. JAI Dining Servs. (Phx.), Inc., 245 Ariz. 578, ¶ 11 (App. 2018).

¶7 On the last day of trial, Kimminau moved for JMOL, asserting insufficient evidence to find he fell below the standard of care, and that Hoopes had failed to establish both the elements of equitable recoupment and her claimed amount of damages.2 The court denied the motion.

¶8 The trial court may grant a JMOL against a party if the “party has been fully heard on an issue during a jury trial and the court finds that a reasonable jury would not have a legally sufficient evidentiary basis to find for the party on that issue.” Ariz. R. Civ. P. 50(a)(1). “Recoupment is an equitable doctrine which can be used to reduce or eliminate a judgment.” Ness v. Greater Ariz. Realty, Inc., 117 Ariz. 357, 360 (App. 1977). It is a defense that “goes to the very existence and foundation of [a] plaintiff’s claim,” and therefore must “aris[e] out of some feature of the transaction upon which the plaintiff’s action is grounded.” Aetna Fin. Co. v. Pasquali, 128 Ariz. 471, 473 (App. 1981) (quoting Bull v. United States, 295 U.S. 247, 262 (1935)). Recoupment cases generally involve some natural equity arising from the transaction, such as a plaintiff’s failure to comply with a cross-obligation of the contract sued on, or some violation of a duty imposed on the plaintiff by law. 20 Am. Jur. 2d Recoupment or reconvention § 5 (2026). In Arizona, it has been used to permit a defendant to recoup damages suffered from fraud, breach of warranty, breach of contract, or negligence on the plaintiff’s part arising out of the transaction in question. See Light v. Chandler Improvement Co., 33 Ariz. 101 (1928) (breach of warranty can support a recoupment defense); W. J. Kroeger Co. v. Travelers Indem. Co., 112 Ariz.

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Kimminau Law Firm, P.C. v. Melody Hoopes, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kimminau-law-firm-pc-v-melody-hoopes-arizctapp-2026.