Elliott v. Videan
In Elliott v. Videan (1989) 164 Ariz. 113, 119-120 791 P.2d 639, the Arizona Court of Appeals held that if "an attorney's negligence is the cause of dismissal of the underlying claim, the proper measure of damages is all compensatory and punitive damages awarded by the jury in the trial of the case within a case."
The court noted that "Arizona has traditionally held that a tortfeasor is liable for all damages that occur as a result of the commission of the tort." (Id., 791 P.2d at pp. 645-646.)
The court rejected the argument that lost punitive damages were unavailable in a malpractice action " 'because of the difficulty a jury may have in arriving at the damages occasioned by the negligence.' " (Id. at p. 645.)