1147 (2014); accord Valley/50th Ave., LLC v. Stewart, 159 Wn.2d 736, 743, 153 P.3d 186 (2007). ¶55 Courts may also deny or disgorge attorney fees in response to an RPC violation. Eriks v. Denver, 118 Wn.2d 451, 462, 824 P.2d 1207 (1992) (“The general principle that a breach of ethical duties may result in denial or disgorgement of fees is well recognized.”); accord Behnke v. Ahrens, 172 Wn. App. 281, 298, 294 P.3d 729 (2012) (stating that “[d]isgorgement of fees is a reasonable way to discipline specific breaches of professional responsibility, and to deter future misconduct of a similar type,” and holding that it was proper for the trial court to limit the sanction for an RPC violation to disgorgement of fees paid); Cotton v. Kronenberg, 111 Wn. App. 258, 272, 275, 44 P.3d 878 (2002) (<HOLDING>). Consistent with the principle that
holding that the trial court did not abuse its discretion in awarding prejudgment interest on attorneys fees paid prior to the entry of judgment holding trial court had no authority to award attorneys fees when arbitrator had stated he would not award attorneys fees holding that the court of appeals erred in modifying the judgment to include attorneys fees when the trial courts refusal to grant attorneys fees was not the subject of a point of error holding trial court erred in awarding attorneys fees to physicians in absence of any evidence of attorneys fees holding that a trial court order disgorging all fees paid was a proper consequence of an attorneys rpc violation