§ 3.7 THE AMOUNT OF ATTORNEYS' FEES RECOVERABLE

• Jurisdiction: Arizona

When the contract provides that the prevailing or successful party shall be entitled to recover its "reasonable" attorneys' fees, the determination of "reasonableness" is within the discretion of the trial court and is subject to review for abuse of discretion. Geller v. Lusk, 230 Ariz. 624, 627, 285 P.3d 972, 975 (App. 2012); Chase Bank, 179 Ariz. at 574-75, 880 P.2d at 1120-21; Harris v. Reserve Life Ins. Co., 158 Ariz. 380, 384, 762 P.2d 1334, 1338 (App. 1988); Woliansky v. Miller, 146 Ariz. 170, 704 P.2d 811 (App. 1985). "'The amount of fees is peculiarly within the trial court's discretion. Appellate courts are hesitant to second-guess the trial court on awards of attorneys' fees in view of the [trial court's] superior understanding of the litigation and the desirability of avoiding frequent appellate review of what essentially are factual matters.'" Chase Bank, 179 Ariz. at 574, 880 P.2d at 1120 (quoting Associated Indem. Corp. v. Warner, 143 Ariz. 567, 571, 694 P.2d 1181, 1185 (1985)); see also North Star Dev. Corp. v. Wolfswinkel, 146 Ariz. 406, 706 P.2d 732 (App. 1985) (the trial court's decision will be upheld on appeal if the fee award is supported by a "reasonable basis"). However, the authority to use a specific method to determine attorneys' fees is an issue of law to be reviewed de novo. Geller, 230 Ariz...