An advance payment is unearned per se, they didn't work for it, they were just given it. Why reiterate that is is unearned?

The way I understand it is that somebody is given an advance payment but did nothing to earn it afterwards, for example it says here

"...for failure to promptly return unearned advance payments of fees after Hammond did not take reasonable steps to advance Mrs. McBratney's case."

Movant v. Maxwell Lee HAMMOND

Otherwise it is a fine example of tautology.

1 Answer 1


An advance payment is given in expectation that it will be earned. In the future when the work has been done the payment is now an "earned advance payment"

It seems that the case is about someone who took an advance and then took no steps towards earning it and presumably did not return it, hence it is "unearned".

There is no tautology here as an advance that happened in the past may be earned or unearned.

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