In re Marriage of Goesel

*232 ¶ 1 At issue is whether fees that have already been earned by an attorney in a dissolution of marriage proceeding are considered "available funds," such that they may be disgorged under section 501(c-1)(3) of the Illinois Marriage and Dissolution of Marriage Act (Act) ( 750 ILCS 5/501(c-1)(3) (West 2014)). We hold that earned fees are not subject to disgorgement.

¶ 2 BACKGROUND

¶ 3 The facts of this case are set forth fully in the appellate court's opinion. 2017 IL App (3d) 150101 , ¶¶ 3-10, 410 Ill.Dec. 797 , 71 N.E.3d 793 . We set forth here only those facts necessary to an understanding of…