Connor v. Cal-Az Props., Inc
In Connor v. Cal-Az Props., Inc., 137 Ariz. 53, 668 P.2d 896, 898 (Ariz. Ct. App. 1983), the Court of Appeals of Arizona discussed policy considerations weighing against allowing an award of attorney's fees to attorneys appearing on their own behalf.
"Courts declining to grant fees under such circumstances have found that one should not become one's own client and charge for professional services and that attorneys representing themselves might be tempted to protract litigation for their own financial betterment." Id. at 898.
The court continued:
In our opinion, the presence of an attorney-client relationship is a prerequisite to the recovery of attorney's fees. . . . Because an attorney has no right to recover compensation in the absence of an attorney-client relationship, the corollary must necessarily be true -- the party who represents himself in litigation has no right to be compensated by the payment of attorneys' fees because of the absence of an attorney-client relationship. Id. at 899.