On Nov. 30, the Illinois Supreme Court, in In re Marriage of Christine Goesel and Andrew Goesel, 2017 IL 122046 (2017), held that earned attorney fees — as in fees received for actual services rendered — are not “available” for turnover, or disgorgement, pursuant to a petition for interim attorney fees brought under Section 5/501(c-1) of the Illinois Marriage and Dissolution of Marriage Act and, thus, resolving a contentious split in the circuits.This article will touch upon the history, as well as …